The study resulted from an exercise CLIA has coordinated in the Baltic Sea in 2016, where it tested the availability and adequacy of Port Reception Facilities (PRFs) in the area. The study determined that based on MARPOL Annex IV Special Area provisions, which are not yet in effect, deficiencies exist at both the port and ship side that need to be addressed.]
The analysis shows that during a significant number of port calls, 46% of the port calls by cruise ships reported a PRF related issue in response to three specific questions. The first question concerned specific issues encountered, namely: “no facility available” (12,7%); “undue delay” (21,8%); “technical issues” (5,9%); “inappropriate location” (5%); “unreasonable charges for use of facilities” (25,5%) or “other” (29%). The latter included aspects like planning and specific port/ship characteristics. During 32% of port calls, cruise ships considered the fees to be disproportionally high, thus creating a disincentive to utilize the PRF.
Cruise ships mixing and treating both Black Water (BW) and Grey Water (GW) (e.g. using advanced sewage treatment systems on board) provided negative feedback on the adequacy of the port facilities, particularly relating to the volume actually discharged at the PRF. CLIA therefore advises all relevant Baltic industry stakeholders to ensure clear communication on the availability of PRFs and record this information in the IMO GISIS database; closer engagement with the cruise industry on the development of port infrastructure and related Waste Reception Handling Plans; adequacy of PRFs in the Baltic Sea Region; development of a contingency / “Plan B” mechanism for exceptional discharges; and using a more detailed standard format of the Advance Notification Form (ANF) for Waste Delivery to Port Reception Facilities. Ports should take into account characteristics of specific cruise ships, including time spent at sea and expected volumes of sewage to be generated. “All stakeholders need to work together to advance environmentally sustainable practices in the Baltic, the 3rd largest cruise market in the world, and ensure that protective environmental measures and business operations are aligned”, commented Tom Fecke, CLIA Europe Secretary General. “We also believe that many Baltic ports will need to update their individual Port Waste Management Plans to account for the impending legislation and include the cruise industry in those discussions, he added.” Fecke also commented that “Legal, safety and environmental risks can only be managed successfully through close cooperation between all stakeholders, especially the ship operators, ports and PRF providers. More long-term partnerships with key PRF providers, where core competencies are very high regarding safety and environment, and this may support managing this operational risk.” Some cruise ships will continue to report on their experiences with PRF for sewage in the Baltic during the 2017 season. For future studies, a deeper involvement of ports in the mapping is strongly recommended by CLIA, in order to get to a full understanding of the investments/interventions needed to ensure the continuity of cruise operations in the region once the Special Area enters into force. Following the presentation, the participants agreed on the need for a dialogue among all stakeholders, and especially between CLIA and the Baltic Ports. This, to ensure clear legal certainty in all key aspects of the implementation of the European Directive on Reception Facilities and, in particular the interpretation of the “next port of call”; which is of great importance to the operators. The discussion stressed the importance of the adequacy of PRFs in the region which should be forward looking and designed to accommodate the future needs of cruise ships in the region accompanied by a "Plan B" to ensure redundancy, as well as a transparent fee structure.
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