It has been most unfortunate for Greece in 2012 to have had to face the most severe crisis of its national economy which has also coincided with one of the deepest crises in the endemic cyclical nature of international shipping. The international shipping downturn has not only been deep but also long in its duration due to three major factors: the
reduction of cargo volumes
overcapacity of tonnage, and theinability of the credit system internationally to provide sustainable finance.
It is much too early to evaluate with any certainty the direction for the immediate future. Our main interest remains focused on the developing countries especially China and India, with the hope of a speedy recovery of international trade. In the face of these objective difficulties we have been called upon as entrepreneurs of the sea but also as Greek citizens to face these challenges with courage and faith in our abilities.
In respect of the shipping straits, as entrepreneurs we have all prerequisites to steer through safely and retain our leadership not only in numbers and size but also in the high quality of service. However, in view of rapid changes occurring in the global economy, Greek shipping is satisfied so far with the dynamic role that it continues to play in the international arena. In June 2012 and for a whole week, the heart of the international shipping industry was beating in the Greek shipping capital due to the Posidonia International Exhibition, bringing once more to the fore the primacy of Greek shipping in global shipping developments as well as its strategic importance since it has the highest percentage of transportation capacity in the world.
At the same time, the Greek Government started the effort for the stabilization of the
national economy. From the very beginning, the shipping community conveyed its support and declared its willingness to contribute to this effort. To this effect, the Greek shipping community has voluntarily offered to contribute over the next three years, for all vessels, under both Greek flag and foreign flags operated by shipping companies established in Greece, the double amount of tonnage tax a Greek ship would normally contribute. This initiative aims at enhancing the fiscal revenues over the next critical period. It is noteworthy that the state revenues have already been given a boosting due to the obligation, as of 2013,of vessels under foreign flag operated by companies established in Greece, to also pay an annual tonnage tax to Greece.
These developments are being implemented within the long established institutional
legislative framework for shipping where shipping is recognised as a non-negotiable, historic national economic and strategic asset, which must remain internationally competitive. As highlighted in a recent study of the Greek Foundation for Economic and Industrial Research (IOBE), the existing contribution of Greek-owned shipping to the Greek economy is decisive but also its potential contribution is equally, if not more important.
Greek-owned shipping can also provide significant employment especially for the growing list of unemployed youth. The appropriate legislative framework is a prerequisite to allow the recruitment of Greek ratings on competitive terms taking into account the international standards.
At the beginning of the second half of 2012, following a succession of failed administrative schemes over a period of two and a half years, an autonomous and independent Ministry for Shipping was re-established, manned predominantly by the
Hellenic Coast Guard which as before will carry out its executive work. This fact was warmly welcomed by the Greek shipping community and it is a confirmation, in practice, of the need for an autonomous Ministry.
Lastly, due to the dire economic situation of Greece, the Union of Greek Shipowners considered necessary to set up, with the financial support of the Greek shipping community, a programme of social welfare and solidarity in order to support a significant part of the population most affected by the crisis. The Greek shipping community has hastened once again as it has done historically on numerous occasions to the assistance of the home country and its citizens, in periods of crisis.
In any case, the adverse economic circumstances existing at national and European level,coupled with the deep recession in international shipping, render imperative the co-operation between the shipping industry and the State, in order to maintain the competitiveness and, hence, the sustainability of Greek-owned shipping. In this way, it may continue, through its establishment in Greece, to remain a major and successful component of the national economy. This is not only our entrepreneurial but, mainly, our national objective. On this difficult path towards the revival of the country, Greek shipping will remain a reliable partner.
GREEK SHIPPING AND THE ECONOMY
In 2012 the European sovereign debt crisis and its worldwide repercussions continued to negatively affect the world economy. Europe entered a mild recession, US growth
was slower than expected and even the world’s fastest growing economy,
China, registered a significant slowdown. Slackening demand, especially for raw
materials and mineral ores led to higher unemployment rates and lower demand for goods.Furthermore, the credit crunch resulting from the debt crisis led to significantly reduced financing capabilities of the international banking system. 2013 is proceeding with a relatively more positive macro-economic outlook than 2012, but depends on the performance of developing countries and the imponderables in the Eurozone which continue to cast a shadow.
More optimism is expressed for 2014 and henceforth.
The Greek economy in its fourth year of recession has led to a 25% decrease of the gross domestic product (GDP) since 2009. Domestic demand has fallen sharply and unemployment at 27% is the highest in Europe.
However, the new Greek government in 2012 re-established confidence in the ability to take the appropriate fiscal and structural measures to overcome the crisis. GDP will continue to slow down for most of 2013 but the recapitalization of the country’s banks and an acceleration of EU financing and direct foreign investment will hopefully reverse the tendency and herald positive growth from the end of 2013 onwards.
Ship finance was even lower in 2012 as major international banks continued their withdrawal from this market.
It was mainly left to funds and to private placements to provide ship finance but the lower freight rates and the consequent reduced value of ships rendered lending even more problematic. As major shipbuilding orders continue to absorb the limited amounts of finance available, major financing problems will persist
in 2013. Despite recession and oversupply of tonnage, Greek oceangoing shipping remained particularly competitive with Greek shipowners controlling over 15% of the world fleet. Its ability for adjustment in ever changing and demanding conditions is witnessed by investments in new ships. However, it is estimated that the shipping crisis may continue in the three coming years.
In 2012, the economic data of the Greek flag fleet were to a large extent satisfactory. The Greek register accounted for 1,939 vessels (over 100 gt) amounting to 43,613,921 gt . The Greek owned tonnage held first position internationally. The fleet amounted to 3,428 vessels (ships greater than 1,000 gt) of 245.14 million deadweight tons, representing 15.56% of total world dwt . The Greek flag fleet ranks sixth internationally (in terms of dwt) and second in the EU (in terms of gt). The Greek owned fleet under EU flags accounts for 42.72% of the EU dwt tonnage. Moreover, Greek owners control 23.55 % of the world tanker fleet (crude oil tankers), 17.20% of the world bulk carrier fleet and 12.51% of the world chemical and product carriers fleet in terms of dwt (excluding ships currently on order).
In January 2013, the Greek Parliament adopted legislation (law 4110/2013), whereby tax was imposed on foreign flag vessels operated by management companies established in Greece. The calculation of the tax is based on the same criteria, rates and percentages in force for Greek flag vessels, less the tax, if any, paid to the vessel’s flag register.
Moreover, the Greek shipping community has committed itself to a voluntary financial contribution, which doubles for the next three years the taxation of Greek flag vessels as well as foreign flag vessels operated by management companies established in Greece. This contribution aims at enhancing the fiscal revenues of
the Greek state over this critical period in support of the Greek economy.
In 2012, the re-instatement of the autonomous Ministry of Shipping and the Aegean, following an administrative gap of four years since its abolition, is a positive development welcomed by the Greek shipping community. New measures provide fast track vessel registration under the Greek flag and slashing through of red tape in order to attract more ships. Thus, administrative procedures in registering ships are standardised and simplified. These measures aim at offering a more viable environment for the wider Greek maritime cluster of activities and enhancing the status of Greece as an international maritime centre.In 2012, Greek shipping remained an important commercial partner of the EU, the US and China which carries a high percentage of world trade efficiently, safely and in an environmentally friendly way. Its prestige provides Greece with a negotiating advantage for the development of strategic alliances in the current difficult period.
COMMERCIAL SHIPPING POLICY
Guidelines on State Aids to Maritime Transport:
The Guidelines on State Aids to Maritime Transport (2004), the cornerstone of the European shipping policy, have successfully enabled individual member states to adopt measures strengthening their shipping sector and improving its competitiveness. The EU fleet operates in an almost free global market exposed to fierce
competition particularly from third country fleets and shipping centres in Asia and the Far East.The Guidelines were devised to create an international level playing field including the EU fleet. Their basic purpose was to address the international competitiveness of the EU fleet and not primarily intra EU competition. The Guidelines have neither distorted intra EU competition, nor affected trading conditions to an extent contrary to the common interest of the EU/EEA . They are the sine qua non of the taxation regime of shipping in the EU.The Guidelines institute a shopping list of benefits including, inter alia, vessel taxation, social security contributions of shipowners / seafarers, maritime education, short sea shipping and promotion of research. In Greece, the only available benefits concern vessel taxation and reduction in social security contributions. The Greek tonnage tax system was
devised in the 1950’s and, being the oldest of its kind, has served as the source of imitation for several success stories of tonnage tax regimes adopted in the EU and beyond since the 1990’s.
In reviewing the Guidelines, the European Commission should focus on the wider industry perspective and global character of shipping competition, rather than the narrow perspective of intra EU competition and the integration of the internal market. The UGS notes that the European Commission acknowledges that “in
globalised markets there is need to have a competition spirit with an international dimension ”. Shipping is one such market. Therefore, the UGS invites the Commission to review the State Aid Guidelines precisely in this spirit. The UGS also notes that the European Commission acknowledges that “competition policy
promotes growth, employment, competitiveness and consumer protection” . All four aims are promoted by the existing Guidelines on State Aids to Maritime Transport. This is an additional reason for their continuation.
The maintenance of the Guidelines framework will allow member states to have measures matching global competition. The Guidelines provide the necessary regulatory certainty in the shipping sector that all businesses require and without it, there is a serious risk of relocation of shipping activities away from Europe
and deflagging of ships from EU flags. Security of investment necessitates maintaining a stable legal regime in conformity with the principle of legal certainty.
Continuation of the Guidelines will maintain a strong competitive EU shipping industry with consequent benefits for the EU’s strategy on security – both military and the supply chain – the economy and employment. Without them, these benefits will not arise. Indeed, the European fleet provides security of the energy supply of the EU and supports military operations and peace – keeping activities. In a period of crisis and high unemployment, the EU fleet provides employment at sea and ashore in a whole range of ancillary maritime activities in the maritime cluster and the application of tonnage taxes improves the employment opportunities of EU seafarers. Employment of EU seafarers is crucial for the maintenance of maritime
know-how in the EU. The Guidelines have boosted the European maritime cluster of activities, namely, seaports, equipment manufacturers, lawyers, bankers, brokers, classification societies, insurers, ship repairs and shipyards. Their application has also promoted the acquisition of younger and more technologically advanced vessels in the EU fleet and, thus, improved its environmental performance. The Guidelines have
also encouraged the promotion of short sea shipping in the EU as an alternative to road transport, relieving road bottlenecks and thus encouraging a modal shift to more environmentally friendly modes of transport. The UGS firmly believes that it is essential for the operation of the EU/EEA shipping, to maintain the existing legislative framework. The European Commission should proceed with the continuation of the current Guidelines on State Aid to Maritime Transport. Shipping as a leading industry should be preserved by the EU in view of its strategic importance and its multifaceted contribution to the EU economy.
Piracy constitutes a serious global threat to regional security, global trade, maritime transport and the world economy but, most of all, a threat to the life and safety of seafarers. Its annual cost is estimated at US $ 7-12 billion.
In 2012, pirate attacks in Somalia and the Indian Ocean registered a steep decline. Despite this, there is no room for complacency of ships and seamen transiting the high risk areas off Somalia, the Gulf of Aden and the Red Sea. According to the International Maritime Bureau there was a decline of pirate attacks of 68%.
More particularly, 75 Somali attacks took place in 2012 as opposed to 237 in 2011 over the same period. Hijacked vessels were down to 14 compared to 28 in 2011. This was due to better policing and intervention of anti-piracy naval forces, better compliance with Best Management Practices (BMP) by ships and the use of
armed guards. However, on 31/12/12 Somali pirates still held hostage 104 seafarers of various nationalities on board 8 vessels and 23 seafarers ashore whilst negotiations were ongoing for their release.
Despite continuous efforts at international and European level for combating the piracy phenomenon the desired results have not been achieved so far. Lack of strong political will in shaping up an effective policy with parallel sensitization of public opinion and of the international and European policymakers account for this. It is encouraging that the United Nations Contact Group on Somalia proposed measures to face all aspects of piracy with relevant submissions to the UN and the IMO. The European Parliament adopted Resolutions and the Report on the EU Strategy for the Horn of Africa aimed at better coordination of the EU institutions entrusted with combating piracy and establishing the rule of law in the sovereign state of Somalia. The European Economic and Social Committee (EESC) adopted an “own initiative” opinion aiming at sensitising the European organised civil society to the serious repercussions of piracy as a means of exerting pressure on governments and the EU for robust action leading to its eradication.
The EU decision extending the mandate of the EUNAVFOR – Atalanta operation until the end of 2014 and extending the high risk area under surveillance is welcomed. The continuation of the presence of naval forces of NATO, the EU and third countries in the high risk areas with reinforced rules of engagement is in compliance with governments’ obligations stemming from the UNCLOS Convention and the decisions of the UN Security Council in safeguarding free navigation in international waters.
Since the root causes of piracy lie ashore in Somalia, it is vital to create the infrastructure for it to function as a sovereign state. In this context, the UGS welcomes the EU CAP - Nestor operation of the European External Action Service (EEAS) and the adoption of a package of actions aiming at reinforcing the financing
of humanitarian aid, educating Somali security forces, creating the necessary legal framework in Somalia and strengthening the maritime capability of neighbouring countries (Kenya, Seychelles, Mauritius, Djibouti) which are affected in many ways by piracy. The UGS maintains that effectively combating piracy requires multifaceted action and a series of measures connecting the use of force with the creation of infrastructure in Somalia.Regarding self protection measures of commercial vessels, the UGS prompted its members for full compliance with the revised Best Management Practices (BMP 4). Its participation in the relevant proceedings of IMO contributed to the drafting of Guidelines for the employment of private armed guards on board vulnerable ships and the promotion through IMO and ISO of the procedure for the standard setting of companies offering maritime security services (ISO PAS 28007). Moreover, legislation allowing the use of qualified Greek private armed guard companies on board Greek flag vessels is in the pipeline. This legislation complements legislation already adopted in 2012 allowing the use of qualified foreign private security companies. Tracing the financial flows of ransoms paid to pirates for the release of hijacked ships and seafarers hostages is being examined by Europol and Interpol including the proposal for an eventual banning of ransom payments to pirates as a means of stopping their financing. The international shipping organisations and the UGS strongly object to this proposal as it may endanger seriously the lives of hostages. In parallel to developments in Somalia, a disquieting escalation of attacks is occurring in the Gulf of Guinea. Although piracy in West Africa has different characteristics from that in Somalia and is likened to armed robbery, there is particular concern that these attacks are more violent taking a toll on lives of seafarers. The UGS in coordination with the Ministry of Shipping and the Aegean supports initiatives by the IMO and other international organisations for the protection of ships and seamen. It also welcomes the European Commission initiative for a programme to assist countries in the Gulf of Guinea to improve security on vital
maritime routes. The UGS in close cooperation with relevant public services and international shipping organisations has contributed to the adoption of decisions by the United Nations, IMO and the EU in combating piracy. Apart from Greece’s initiative to highlight the piracy problem in the European Parliament in order to sensitize policymakers, the UGS through ECSA supported the need for a wide spectrum of possible EU actions (e.g. food aid, development aid, military engagement) to restore the rule of law in Somalia.
GUIDELINES ON COMPETITION RULES FOR MARITIME TRANSPORT
The UGS believes that global compatibility of competition rules is required for a global industry like shipping. In the liner sector, global developments in antitrust law indicate a trend towards retention of the liner conference system (wherever it exists) subject to conditions. In the EU, the year 2012 was marked by the review of the maritime antitrust Guidelines which was concluded in January 2013. The European
Commission launched an on line consultation on the future of the Guidelines on competition rules for maritime transport (2008) that covered liner shipping, tramp vessel services and cabotage (e.g. information exchanges between competitors in the liner sector and horizontal cooperation between tramp operators in
pools). The Commission wishes to streamline the specialized Guidelines for the transport sector and other sectors with its general antitrust policy. The consultation revealed that the stakeholders shared the European Commission’s views that the main purposes of the maritime Guidelines had been achieved. Indeed, the maritime Guidelines have safeguarded a smooth transition from the block exemption of liner conferences to the self assessment by shipping companies of their agreements. They provided Courts and maritime practitioners with guidance in dealing with EU antitrust law on maritime transport. Application of the general antitrust Guidelines to maritime transport would increase clarity and legal certainty by eliminating potential discrepancies between the maritime Guidelines and the general Guidelines, thus, leading to legislative simplification.
The UGS supported the suggestion of DG COMP to rely on the guidance of the general antitrust Guidelines provided that the following aspects are taken into consideration:
• Regarding liner trades, the maritime Guidelines demise should not entail the lapse of the maritime consortia block exemption Regulation upon its expiry in 2015 which should be retained.
• The bulk sector amounting roughly to 75 % of international maritime transport is a “terra incognita” in terms of antitrust law. It is a vast sector guided by the unfettered application of the law of supply and demand mainly due to the very large number of predominantly private shipping companies involved. In economic terms it is characterised as a sector of “perfect competition” being a de-regulated and globalised market subject to high volatility of freight rates. The absence of complaints in this sector is testimony to its free conditions of competition.
Bulk pools within the tramp sector emerged as a market response for small and
medium size operators to survive in times of crisis taking into account the endemically cyclical nature of the shipping market. The maritime Guidelines offered guidance to those tramp operators engaged in pools (a small segment of the tramp bulk shipping market) for the assessment of their pool agreements which is needed due to the absence of case law in the tramp sector.
• The general Guidelines should be reviewed frequently to take into account subsequent jurisprudence on maritime competition emanating from the European Court of Justice and DG COMP. They should include the definitions of liner shipping, tramp vessels services, consortia and bulk pools either in a footnote or in an Annex for the sake of legal certainty. In January 2013 the European Commission announced that it will not renew the maritime Guidelines when they lapse on 26/9/13. However, it remains unclear if the definitions mentioned above will be accommodated in a legal text.
LIBERALISATION V. PROTECTIONISM IN MARITIME TRANPORT
Although international maritime transport services are nowadays more liberalised than most other services sectors, there is a trend in some geographic areas to resort to a variety of protectionist measures purported to facilitate their commercial interests and to support their shipping sector. This trend was boosted after the failure of WTO negotiations for an international agreement on trade liberalisation. In the services sector, including maritime services, negotiations reached an impasse and
have been suspended since 2011. Many of the 25 obstacles to trade identified last
year by the European Commission are still in place. Not only several longstanding
obstacles have still not been raised, but several new measures distorting trade were
taken in 2012 by the EU’s strategic partners (e.g. US, BRICS ) which account for 40% of exports.
Maritime transport, as a par excellence international activity, requires a free and stable
global regulatory framework guaranteeing the unrestricted and non discriminatory access of vessels to the worldwide movement of cargoes in conditions of free competition. The revival of protectionism threatens to create uneconomic shipping activity and burdening cargo movements with additional costs to the detriment of world prosperity.
The UGS supports the European Commission initiatives to conclude either bilateral maritime agreements with important trading countries (e.g. China, India) or Free Trade Agreements with a considerable number of countries. Such agreements will safeguard liberalisation of maritime transport services based on the principle of national treatment for both tramps and liners. The UGS also welcomes the EU / US initiative to start negotiations for the conclusion of a “Transatlantic Trade and Investment Partnership”. It is essential to include maritime transport services in the trans-boundary trade in services. This comprehensive agreement should safeguard maximum liberalisation and favourable conditions regarding market access of maritime services.
Moreover, the UGS endorses the recent initiative of 22 countries entitled “Real Good Friends of Services” (RGFS) representing almost two thirds of world transactions in transboundary trade in services to conclude a multilateral agreement liberalising trade in services. This agreement based on the standstill principle and the GATS provisions can be the vehicle through future accessions of several developing countries for the setting up of a “critical mass” which could subsequently be integrated in the WTO mechanism. It is hoped that the potential for enhanced growth and employment of these liberalis
In 2012 1,161 places offered by the Marine Academies attracted about 4,75 1 candidates. The combined effect of the campaign for attraction to the seafaring profession and high unemployment ashore contributed to this spectacular result.
The national economic crisis exacerbated by the severe downturn in shipping
took a heavy toll on maritime education in 2012. The recent establishment
of a Career Office at the Ministry of Shipping and the Aegean will assist
in channelling cadets to Greek-owned vessels. The expected recognition of private maritime schools alongside Public Marine Academies will provide an opportunity for more job creation at sea to combat severe youth unemployment ashore. This is all the more necessary in view of the incapacity of Public Marine Academies to provide education to increased numbers of cadets.
MARITIME LABOUR CONVENTION
The establishment of private maritime education alongside Public
Marine Academies will provide an opportunity for more job creation and combat youth unemployment
The entry into force on 20/8/2013 of the ILO Maritime Labour Convention 2006 (MLC) complements the institutional environment governing shipping operations internationally. Taken together with the international Conventions of IMO, MARPOL, SOLAS and Standards of Training Certification and Watchkeeping of Seafarers (STCW) it will create a uniform and comprehensive framework for maritime transport internationally. In 2012 Greece ratified this fundamental Convention which guarantees the conditions and labour
rights of seafarers on board ships as well as their social security. The implementation of the Convention poses challenges as to the uniform interpretation of its provisions
and thereby safeguarding its aims. The UGS, together with the Ministry of Shipping and the Aegean and the Panhellenic Seamen’s Union, are initiating complementary regulatory provisions in order to avoid problems for Greek vessels in foreign ports regarding their compliance with the MLC requirements.
The 18th Conference of the United Nations Framework Convention on Climate Change (UNFCCC-COP18,
26/11-8/12/12) in Doha, Qatar, could not reach agreement on cooperative sectoral approaches and sectorspecific
actions regarding CO2 emissions. Once again, Parties highlighted the need to avoid unilateral
measures in addressing emissions from maritime and air transport and emphasized that this issue should be
considered multilaterally through IMO and ICAO .
The UGS welcomed the EU official acknowledgment concerning the non feasibility of an Emissions Trading
Scheme (ETS) for CO2 emissions from maritime transport. The retraction of a similar EU attempt for civil
aviation - as a result of the international outcry and decisive US action - constituted a precedent to be heeded.
In IMO, increasing doubts on the necessity, purpose and scope of a Market Based Measure (MBM) for the reduction of CO2 emissions from shipping have shifted the focus to addressing two important associated issues: Agreement on the promotion of technical co-operation and transfer of technology relating to the
improvement of the energy efficiency of ships and on the work to update the inventory of greenhouse gases (GHG) from international shipping. These doubts have also given rise to proposals for alternative emission reduction schemes based on the actual efficiency of ships, such as the US proposal for the introduction of mandatory efficiency standards for all ships. The proposal is supported by a group of countries favouring the establishment of a system of mandatory efficiency indexing for existing ships. The UGS believes that it would be unwarranted and completely inappropriate to extend the application of EEDI to the existing fleet, either by way of an MBM or as an interim or complementary measure for emissions
reductions. Tramp bulk operations do not have the predictability or regularity that would make such an application appropriate or workable.
The shipping industry welcomed the decision of the European Commission to refrain from imposing on international shipping regional climate change measures and to pursue instead a global agreement in the IMO. Its initial plan to establish a system for monitoring, reporting and verification (MRV) of emissions from international shipping could be useful in the context of the IMO future discussions on further measures to reduce CO2 emissions from ships. However, it seems that the ultimate goal is to collect data in order to achieve emission reductions by
mandating energy efficiency measures for all ships which the UGS does not support.
The UGS believes that any mandatory requirements on MRV must be accurate, simple, cost-effective and workable both for the industry and for the authorities. The system should be exclusively based on the vessels
fuel consumption and not on arbitrary efficiency ratings for existing ships, especially in the tramp/bulk sector. The industry does not need an inflexible regulatory scheme to reduce fuel consumption, while market forces are the strongest driver to that end. Moreover, conditional support for an MRV mechanism does not imply acceptance of its development into a market based measure.
Sulphur Oxides and Black Carbon Emissions
The long awaited new Directive 2012/33 amending Directive 1999/32 as regards the sulphur content of marine fuels is the culmination of intense consultations and negotiations. Although the revised Directive was necessary in order to harmonize the EU legislation with the IMO regulations for sulphur emissions from ships under MARPOL Convention Annex VI, it still contains certain elements that exceed the IMO requirements. The Directive opens the door for the use of emission abatement methods (LNG, exhaust gas cleaning systems -scrubbers- and onshore power supply) as alternatives to the use of marine fuels. However, these alternatives may not be widely available before 2020 and the possibilities of financial measures in favour of affected operators will be rather limited and uncertain.
The UGS supported the efforts of the shipping industry to address through the Directive or through the IMO the significant challenges for both governments and industry regarding the use of fuel with sulphur content up to 0.10% in the Emission Control Areas (ECAs) from 1/1/2015. Unfortunately, the European Commission’s lack of support means that no solution has yet been found to a problem that may have serious repercussions for European citizens.
The great potential of using the Northern Sea Route (NSR) as an alternative between Asia and Europe has raised environmental concerns over the impact on the Arctic of emissions of Black Carbon (soot) from shipping. Black Carbon is not currently regulated under the Kyoto Protocol or its parent treaty, the 1992 UNFCCC. Hence, it would be premature to consider control measures to reduce emissions before an appropriate definition for Black Carbon and measurement method have been developed by the IMO.
When the IMO Ballast Water Management Convention (2004) enters into force in the near future administrations and industry will be faced with significant challenges identified a long time ago. The future implementation and enforcement of the Convention with its retroactive compliance dates and reliance on technology not available at the time of adoption are bound to be problematic. Concerns have been raised regarding the proper approval and availability of ballast water treatment systems, the schedule of compliance of existing ships and the ballast water sampling and analysis procedures for port State control purposes.
IMO is compelled to positively address serious concerns over aspects of orderly compliance and realistic controls of ships by port State control officers. Unless there are clear grounds for testing the efficacy of systems, port State control should be limited to the inspection of the Ballast Water Management Plan, the Type Approval Certificate and the Ballast Water Record Book. Hence, the UGS welcomes the agreement on the sampling procedures and analysis protocols and more importantly the establishment of a trial period after the entry into force of the Convention. This pragmatic approach should be coupled with setting new compliance dates to allow gradual compliance of the world fleet.
The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009) which was developed by IMO in close co-operation with ILO and the Basel Convention and with significant input from the shipping industry organizations affords a realistic, well-balanced and workable solution to ship recycling. The Convention provides a level of control and enforcement at least equivalent, if not superior, to that provided by the Basel Convention (on the Transboundary Movement of Hazardous Wastes). The completion by the IMO of the set of associated guidelines will assist ship-recycling facilities and shipping companies to meet the requirements of the Ship Recycling Convention.
Regrettably, despite calls for early ratification, the Convention may be subject to a prolonged entry into force period as it has only been signed by five States. This delay may prompt unilateral action, as indeed has occurred in the EU with the proposed Regulation on Ship Recycling. The UGS concurs with the industry belief that the primary objective of the EU should be to ensure the speedy global entry into force of the Convention as a means of raising standards in recycling States. This can be facilitated with the proposed EU Decision requiring Member States to ratify or to accede to the Convention in the interest of the EU. The UGS acknowledges the keen interest of the European Commission and the reasoning for its proposal that would also replace the existing Regulation on shipments of waste.
However, the potential introduction of regional European obligations, such as the banning of the ‘beaching’ method, which exceed the IMO requirements, will deter ratification especially by ship recycling States. Such an eventuality would not be in the best interest of the environment nor the orderly recycling of ships completing their commercial life.
The UGS is concerned about a series of fatal accidents of bulk carriers attributed to cargo liquefaction. It appears that shippers misdeclare the moisture content of nickel ore / iron ore fines. This uncertainty cannot be waived entirely by using independent surveyors to sample and test the cargo, especially when cargoes such as nickel ore or iron ore fines, are exported from remote and difficult to access locations, which also lack appropriate testing laboratories. Regrettably, liquefaction of such cargoes is the cause for the loss of intact stability due to cargo shifting, which is believed to have contributed to a number of fatal casualties.
Progress has been made in IMO in rendering the pertinent provisions of the IMSBC1 Code more stringent since 2011 when the Code became mandatory. Amendments to it, including a nickel ore schedule, and relevant draft guidelines are to be adopted in June 2013. Regarding the iron ore fines schedule little progress has been made pending the outcome of significant research being carried out in Australia and Brazil.
The UGS believes that co-operation of shipping organizations (especially ICS and Intercargo) with the IMO is of the utmost importance in curbing this disquieting trend. Until finalisation of the relevant IMO schedule, awareness of all stockholders involved including shippers, masters and administrations should be heightened for accident prevention.
In 2012, the UGS undertook initiatives to respond to the critical socioeconomic problems hitting a major part of the Greek society as a result of the deep and protracted recession that Greece is undergoing. More particularly, the General Assembly of the UGS decided to mobilize the Greek shipping community for the economic support of the most vulnerable segments of society.
The UGS set up a social welfare programme and implemented the first round of solidarity action focusing on families, children and youngsters. Using as a yardstick the effective support of Greek society, the following axes were selected: catering, health and maritime education as well as a series of specific support measures addressed at providing substantial support to large parts of the needy population in Greece.
More particularly, the social welfare and solidarity programme:
• Supports on a monthly basis thousands of families with underage children which have been hit by the crisis with an extensive catering programme implemented in the entire territory according to predetermined criteria.
• Caters for the provision of health services to residents of continental Greece and the islands facing obstacles in access to health services for economic or social reasons, under an annual programme of visits of mobile health units of “Doctors of the World”.
• Undertakes support action of annual basic operational needs of welfare centers for children and of stakeholder organisations undertaking social work which are in economic difficulty.
• Re-inforces maritime education through undertaking the costs of repair work and upgrading of material / technical infrastructure of the installations of Merchant Marine Academies. The social welfare and solidarity programme rallies the Greek shipping community around a panhellenic effort maintaining social cohesion to face the dire situation. Moreover, it supports the commitment of the UGS in continuing the longstanding tradition of contribution by Greek shipowners, collectively or individually, in periods of great need of the country.
Since 1916, the Union of Greek Shipowners (UGS) has been representing Greek-owned commercial vessels over 3,000 GT under the Greek and other flags. Greek shipping carries cargoes between third countries (cross trading) overwhelmingly in the tramp / bulk sector (i.e. bulk carriers, tankers, LNG carriers) whilst its container fleet is mainly chartered by liner operators of other countries. As the international representative of the Greek shipping community the UGS promotes balanced and realistic solutions on all aspects of maritime transport (e.g. commercial, technical, social).
The UGS is a member of the European Community Shipowners’ Associations (ECSA) and participates in the European Economic and Social Committee and in the Greek Economic and Social Committee. It is also a member of the International Chamber of Shipping (ICS), the International Shipping Federation (ISF) and maintains a close working relationship with the International Association of Independent Tanker Owners (INTERTANKO), the International Organization of Dry Cargo Owners (INTERCARGO) and the Baltic and International Maritime Council (BIMCO). The UGS follows developments in the International Maritime Organization (IMO), the International Labour Organization (ILO), the Organisation for Economic Co-operation and Development (OECD), the United Nations Conference on Trade and Development (UNCTAD), the International Chamber of Commerce (ICC), the International Maritime Bureau (IMB) – Piracy Reporting Centre as well as in the United States through a permanent representative in Washington D.C. The UGS maintains relationships with the Hellenic Chamber of Shipping, the London-based Greek Shipping Co-operation Committee (GSCC) and HELMEPA (Hellenic Marine Environment Protection Association) which promotes the raising of environmental awareness regarding protection of the marine environment in Greece and abroad.
Co-operation among national shipowners’ organizations under the auspices of ICS, the umbrella association of associations, is of paramount importance for the UGS. In 2012, the UGS maintained close contacts with other national shipowners’ organisations and competent authorities of leading maritime countries. Forging global co-operation is important for shipping, a globalised activity, which is par excellence exposed to geopolitical changes and economic uncertainty. At a time of unprecedented and widespread economic crisis, like the present one, synergies and close cooperation of all stakeholders and institutions involved are imperative. To this effect, the UGS visited the EU institutions in Brussels in 2012 and maintained its traditional close ties with the European Parliament and the European Commission. The UGS met with individual classification societies and P&I Clubs, the International Association of Classification Societies (IACS), the International Group of P&I Clubs and representatives of the hull insurance market.
At national level, the UGS collaborates closely with the state and seafarers’ organisations on a wide spectrum of issues ranging from competitiveness of the national register to seafarer recruitment and maritime education.
The Maritime Exhibition “Posidonia”, organised every two years under the auspices of the UGS, provides a unique opportunity to project the image of Greece as a leading maritime centre worldwide. Posidonia 2012 with a record participation of exhibitors and delegations confirmed the importance of the Greek maritime cluster for Greece, the EU and the world at large.
The “Hellenic Maritime Day” is an initiative of Greek shipping organisations (the UGS and the Hellenic Chamber of Shipping) and the Panhellenic Seamen’s Union which decided, in co-operation with the state, to honour the Greek pioneers of the largest shipping sector worldwide. The third official celebration on the occasion
of the Hellenic Maritime Day and the European Maritime Day (20/5/2013) promoted the contribution of Greek shipowners, seafarers and personnel of shipping companies to the dynamic course of shipping over the years as well as to the Greek economy in general. During this celebration, the memory of distinguished personalities of the Greek shipping community was honoured for their decisive contribution historically to the progress of Greek shipping.
Source: Union of Greek Shipowners