Page 94: of Maritime Reporter Magazine (November 2012)

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Advanced Shiphandling in Manned ModelsMassachuse s Mari  me Academy o  ers the USCG approved Advanced Shiphandling in Manned Models course. This training meets STCW requirements for assessing Management Level Deck O  cers. Addi onal Training at MMA: OPA-90 Quali Þ ed Individual Vessel/Company/Facility Security O  cerVisual Communica  ons (Flashing Light) STCW Basic Safety Training Medical Care/PIC Fast Rescue Boat Radar Observer ARPA/BRM Hazwoper ECDIS Contact us for a complete training schedule Tel: 508 830 5005 Email: cmt@mari  me.edu www.mari  me.edu/cmt The EPA?s Proposed 2013 Vessel General Permit (VGP) will re- quire vessel owners and opera- tors to adoptenvironmentally-acceptable lubricants (EALs) into their operations to further re-duce their environmental impact starting in December 2013. This regulation brings a two-fold benefit to the industry by boosting the bottom line of both smalland large vessel operations, while engen- dering positive change that ensures the preservation of ecosystems in which these vessels operate. The directives put forth in the 2013 VGP will incentivize ac- tion that is not only environmentally eth- ical but also can bring additional profit to the bottom line. Let?s examine the spe- cific language of the 2013 VGP, as it re- lates to lubricants:All vessels constructed on or after De- cember 19, 2013 must use an environ- mentally acceptable lubricant in alloil-to-sea interfaces. ?Environmentally acceptable lubricants? means lubricantsthat are ?biodegradable? and ?non-toxic? and are not ?bioaccumulative.? For all vessels built before December 19, 2013, unless technically infeasible, owners/op- erators must use an environmentally ac- ceptable lubricant in all oil to seainterfaces. Who is affected by the 2013 VGP? The wording of the 2013 VGP is pur- posefully broad. ?Vessels,? as referenced in the 2013 VGP, covers ?every descrip- tion of watercraft or other artificial con- trivance used as a means of transporta- tion? on U.S. waters. The reach of the 2013 VGP spans the globe ? touching any vessel owner/operator whose busi- ness depends on traveling through U.S. waters. This article will serve to detail who will be affected and how these new regulations will impact their business op- erations.What will replacing conventional lubricants with EALs cost?Every vessel that does not currently use EALs in all oil-to-water interfaces will experience incremental costs associated with phasing in environmentally-accept- able products, but in the scope of yearly vessel operations, the increase is virtually negligible. The EPA upper-bound pro- jections estimate a 120% cost increase and their lower-bound projections es- timate an increase of 50% for an aver- age annual increase of $555 to $1,111 per vessel (see table below) . Of course,depending on a vessel?s lubricant con- sumption rate and the type of EAL se-lected, costs will vary.To put these fractional cost increases into perspective, Nordic American Tankers, a major inter- national tanker company, announced net voyage revenue per vessel per day of $16,200 in its Q2 2012 report. Using the?high-end estimate? from the EPA of the annual costs of phasing in EALs to tankbarges and tank ships, it would take slightly over one hour of voyage time per vessel to recoup these costs. Disregarding the substantial return-on- OPINIONFUELS & LUBESProposed 2013 VGP Links Enviro Stewardship to Long-Term Growth Chart 1EPA, Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit http://www.epa.gov/npdes/pubs/vgp_economic_analysis_draftpermit2011.pdf Source: Environmental Protection Agency (EPA), Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit, 83 94Maritime Reporter & Engineering News MR#11 (90-97) R:MR Template 11/5/2012 2:44 PM Page 94

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