◄ عیار سنجی اقدامات ۱۰ سال گذشته مسئولان سازمان بنادر و دریانوردی در بخش معاونت امور دریایی

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رضا محمد علی بیگی: عیار سنجی تفکر، سیاست ها و اقدامات ۱۰ سال گذشته مسئولان سازمان بنادر و دریانوردی در بخش معاونت امور دریایی با محوریت بخش های ایمنی و حفاظت دریایی و نیز سازمان های تخصصی و بین المللی از طریق تحلیل هشت بیانیه قرائت شده توسط نماینده این سازمان در دوازدهمین اجلاس کمیته فرعی پیشگیری و مقابله با آلودگی دریا (PPR12) که از ۸ تا ۱۲ بهمن ماه ۱۴۰۳ در لندن مقر سازمان بین المللی دریانوردی برگزار شد، به جامعه دریایی ایران کمک می نماید تا قضاوتی درست بر عملکرد این بخش از معاونت امور دریایی سازمان بنادر و دریانوردی داشته باشند. محتوای ۸ بیانیه قرائت شده توسط معاون امور دریایی سازمان بنادر و دریانوردی عینا در ذیل آورده شده است. 

بیانیه های دولت ج.ا. ایران در دوازدهمین اجلاس کمیته فرعی پیشگیری و مقابله با آلودگی دریا 

۱- بیانیه در روز افتتاحیه اجلاس PPR12: مربوط به کشتی Galaxy leader :

In the Name of God, the Compassionate, the Merciful.

Thank you Chair

I would like to express Condolences to the two IMO family member who have recently passed away.

Congratulation You Madam Chair on Starting your role as Chair.

Congratulations to the Secretary-General and all countries for their efforts toward the freedom of the seafarers of the Galaxy Leader. 

This matter once again highlights the collective efforts toward an important issue. Therefore, I extend my congratulations once again to all the stakeholders involved in this matter.

It is regrettable that, once again, the representative of the America have abused the IMO platform to further its political agenda, by disseminating falsehoods and deliberate disinformation, and levelling unfounded accusations against the Islamic Republic of Iran regarding the current situation in the Region. It is important to comment based on the facts and avoid making political accusations without evidence.

The Islamic Republic of Iran is committed to Resolutions 2140 and 2216 of the Security Council and has never taken any measures in violation thereof, such as sales or transfer of arms. Moreover, my country always endorses a peaceful resolution of the crisis through diplomatic channels and highlights its dedication to ensuring and promoting maritime security and freedom of navigation.

The United States cannot deny or cover up the incontestable reality that recent incidents in the Red Sea are directly related to their measures.

۲- بیانیه در خصوص دستورکار ۱۱ :  مربوط به حمل و نگهداری گلوله های پلاستیکی در دریا:

Statement on PPR Document 12/11/3

Thank You Madam Chair

We have closely followed the discussions regarding the path forward for the relevant instrument. In alignment with the proposals put forth by several delegates, we recommend that all options be evaluated alongside their respective pros and cons. Meanwhile this delegation believes that proper packing and transportation of plastic pellets would prevent the issue of their desertion at sea.

Additionally, we propose the development of comprehensive guidelines and the sharing of best practices from countries that have successfully implemented similar measures.

After a phase dedicated to capacity-building and knowledge exchange, we can advance towards establishing a formalized and regulated framework under a convention.

This incremental approach ensures inclusive progress and fosters effective collaboration among all stakeholders.

۳- بیانیه در خصوص دستورکار ۱۱: مربوط به توسعه مقررات الزامی برای نشان گذاری ادوات ماهیگیری:

Statement on PPR Document 12/11

Thank You Madam Chair,

Thanks for all efforts of correspondence group, With respect to the efforts made by the correspondence group, we must acknowledge that regulating the fishing gear and reporting to the IMO requires deeper investigation and greater preparedness from fishing vessels and their owners. At the time being, however, the necessary infrastructure and capabilities for the effective implementation of this process among the fishing community are not sufficient.

Regulating or establishing a framework for compliance with laws and accountability requires a supervisory framework to track progress and receive feedback, which needs the use of human, financial, administrative, and supervisory resources. However, the reality is that it is unclear what percentage of the fishing community and fishing vessel owners are prepared to accept regulation, compliance, and accountability, and this can lead to serious challenges in the implementation, enforcement, and monitoring of requirements, especially in technical, financial, and operational approaches. In any case, developing requirements without considering financial assessments and material support is not justified, as a wide range of stakeholders, including local communities, industry representatives, and NGOs, will be involved, while it is still unclear which authority will be responsible for providing these financial resources and oversight.

Furthermore, implementing legal requirements without providing the necessary basic and specialized training will not only be inefficient, but may also have negative impacts on the environment and fishing industries. 

Therefore, it is essential to consider these components and provide practical and specialized training for fishermen and fishing vessel owners.

In this regard, this delegation proposes that before deciding to approve any requirement or legal system, training and empowerment programs should be prioritized to ensure that all stakeholders can properly and effectively comply with these requirements and, as a result, contribute to the protection of the marine environment.

We believe that moving through these stages requires close cooperation between governing bodies, NGOs, and the fishing community to achieve a practical and sustainable solution.

۴- بیانیه در خصوص دستورکار ۱۱:  مربوط به توسعه مقررات الزامی برای نشان گذاری ادوات ماهیگیری:

Statement on PPR Document 12/11/8

Thank you Madam Chair,

The issue of marking the fishing gear has been raised as one of the main requirements for better management of marine resources and prevention of marine pollution. However, due to the technical complexities in developing regulations, as well as the imbalance between the development of environmental protection laws and the structure of fishing vessels, especially in developing countries, marking the fishing gear in the current state of the fishing industry will practically generate greater challenges, such as the method of operational implementation, especially in international waters.

Therefore, considering that no accurate study has been done on the expansion and development of laws and the structural construction of fishing vessels in the recent years, and also considering that the training of personnel of these vessels for the protection of the marine environment requires short-, medium-, and long-term planning, it is therefore suggested that a working group be formed to work on the existing challenges in the structure of fishing vessels, fishing gear, and operational solutions in order to prevent the loss of this gear at sea.

۵- بیانیه در خصوص دستورکار ۷: مربوط به اعمال ممنوعیت بر روی سیستم های گاز خروجی EGC :

Statement on PPR Document 12/7/3

Thank you, Chair.

While supporting the document submitted by ICS, and considering that the installation of EGC systems is a solution for reducing air pollution from ships, based on paragraph 12.1, shipowners who have equipped their vessels with EGC systems in compliance with the relevant regulations would not be unfairly penalized. Furthermore, implementing stricter measures or prohibiting the use of EGC systems requires the presentation of clearer evidence and justification.

Regarding paragraph 12.2, data sharing by countries based on the experience of implementing the MEPC.1/Circ.899 guidelines can contribute to transparency in executive decisions and encourage countries to develop more efficient and improved EGC systems. It can also strengthen trust among stakeholders.

As for paragraph 12.3, we believe that, in line with the overall goal of continuous improvement in maritime technology while adhering to environmental considerations, including criteria for improved design and construction requirements for EGC systems on new vessels will lead to higher performance of these systems and reduced impact on the marine environment. In this regard, specialized working groups such as GESAMP, can play an effective role in providing a scientific basis and research for these updates. 

۶- بیانیه در خصوص بیانیه در خصوص دستورکار ۱۰:  مربوط به اصلاحات به ضمیمه ۴ مارپل:

Statement on PPR Document 12/10

Thank you, Chair

This delegation hereby expresses concerns regarding the implementation of stricter new performance standards outlined in PPR 12.10, related to the amendment of MARPOL Annex IV. Specifically, the newly proposed requirement risk imposing unduly stringent demands upon currently installed STPs.

We noted that the disadvantages and risks associated with implementation the new proposed amendment, such as increased costs, technological challenges, and regional dispraise, should be carefully considered. Balancing stringent environmental protections with practical, flexible, and equitable compliance measures will be critical to ensuring that the amendments achieve their intended goals without disproportionately burdening stakeholders.

One of our main concerns is the financial burden on operators. The proposed amendments introduce significantly higher compliance costs, particularly for small and medium-sized treatment plants. Upgrading existing infrastructure to meet the new effluent standards will require substantial capital investment, and these costs could force many operators, particularly those with older or smaller facilities, to either shut down operations or pass the financial burden onto consumers.

Another concern is about technological challenges and inequities. The amendments place undue reliance on advanced technologies that may not be accessible or affordable for all marine sewage treatment plants. In many regions, namely developing countries or small-scale operations, there is limited access to cutting-edge treatment technologies. Moreover, the rapid pace of technological innovation in this sector means that treatment plants could quickly find themselves outdated and unable to afford continual upgrades.  

Obviously, these existing STPs were designed and approved based on the prevailing performance requirement established by the IMO at the time of their installation. The retroactive application of the updated requirement, as proposed by PPR 12.10, poses significant economic and technical challenges for the existing vessels. The required modification for these systems to meet the new standards would be burdensome and costly.

Therefore, in consideration of the challenges associated with full immediate compliance with the revised standards, we propose the exploration of alternative means of ensuring the continued efficacy of these systems, such as experimental evaluations of their treatment effectiveness. These methods would offer a pragmatic approach that is less burdensome and costly to implement, while simultaneously ensuring that the existing systems continue to operate at a level that protects the marine environment in line with IMO objectives.

۷- بیانیه در خصوص بیانیه در خصوص دستورکار ۱۰:  مربوط به اصلاحات به ضمیمه ۴ مارپل:

Statement on PPR Document 12/10/4

Thank you, Chair

The proposed amendments and associated guidelines for MARPOL Annex IV reflect a commendable effort to strengthen environmental protections. However, implementing these changes, particularly for existing vessels, presents significant challenges that need to be addressed to ensure balanced and effective outcomes.

Existing sewage treatment plants (STPs) were not originally designed for the integration of monitoring devices or compliance with updated testing protocols. Retrofitting these systems may require extensive modifications to piping and sampling points, which will be difficult and time-consuming for existing ships, and will probably drive them out of operation.

Retrofitting costs are substantial, particularly for small fleet operators or older vessels approaching the end of their operational lifespan. This includes expenses for new equipment, installation, and ongoing maintenance. The incompatibility of new monitoring systems (under various brands) with their existing counterparts is also challenging, and it must be borne in mind that the approval of the amendments proposed in PPR 12-10 will affect the sizeable number of existing vessels that need to comply with the new requirements.

Retroactive application of new requirements creates regulatory uncertainty, which would in turn disappoint investors that have ordered new ships to be built and will receive ships that do not comply with the new requirements any more.

The introduction of SMP and SRB requirements is a practical step. However, the associated administrative workload could burden small operators and older vessels disproportionately. Hence, it is necessary to simplify SMP and SRB requirements for smaller vessels and provide clear templates to minimize administrative overhead.

While we commend the environmental objectives underpinning these amendments, their practical implementation must be carefully managed. A phased approach, voluntary measures for existing vessels, and simplified administrative requirements can help achieve these goals without overwhelming shipowners. This delegation therefore urges the Sub-Committee to consider these recommendations to ensure a balanced and effective transition to updating MARPOL Annex IV.

۸- بیانیه در خصوص دستورکار ۳:  مربوط به مقررات شستشوی مخازن طبق ضمیمه ۲ مارپل:

Statement on PPR Document 12/3/1

Thank You Madam Chair

Thanks Belgium, Netherlands , Spain and United Kingdom for Document PPR 12/3/1

As indicated in this document We support the implementation of prewashing requirements for Faty Acid Methyl Esters products under MARPOL Annex II.

Also we recommend some additional considerations for inclusion in the next ESPH ( Evaluation of Safety and Pollution Hazards of Chemicals) Technical Group discussions:

1. Given the increasing global use of biodiesel and FAME blends in maritime transport, it is essential to clearly define FAME's classification under MARPOL Annex II (Category X, Y, or Z)

2. Specific and detailed guidelines should be provided for the prewashing of FAME products, particularly in cases where mixtures or additives are involved, to avoid operational confusion and ensure environmental safety.

3. Consider revising the rules for residue disposal to account for the biodegradability of FAME products, balancing operational efficiency with environmental protection measures.

4. Introduce comprehensive instructions for tank cleaning post-FAME carriage to align with MARPOL’s “discharge to sea” prohibitions, ensuring that any residual materials, which may still pose hazards, are managed appropriately.