American Bureau of Shipping
ABS
American Bureau of Shipping is a not-for-profit organization created under statute in New York in 1862.
ID: 571512824425-85
Lobbying Activity
27 Aug 2024
Having considered the delegated regulation, you may find our feedback below: The term "permanently connected to a port." should be defined An example should be provided as to how a company will report in Thetis a voyage involving "a stop at any offshore facility (e.g. Single Points Mooring SPM) located outside port areas but permanently connected to a port." It is strongly suggested to consider creating a digital platform where, for locations without UN/LOCODE, companies to have to pre-apply to EMSA for such locations to be accepted by EMSA and upon acceptance the location to be added in the platform and assigned a code. Subsequently, such code to be applied during reporting. In the same regard, within the definition of port of call in the existing wording of the regulation, it is stated that ship-to-ship transfers carried out outside ports are excluded. Although the suggested clarification focuses on the offshore facilities, a conflict should be avoided in regard to this. It could be more prudent if the aforementioned is amended to include the existing STS wording, to the following : ship-to-ship transfers or transfers with offshore facilities carried out outside port and without a UN/LOCODEare excluded. Furthermore, when an offshore facility has a UN/LOCODE, it is considered port (i.e., Prelude in Australia). However, offshore terminals like FSRU Toscana and FSRU Alexandroupolis that are located more than 10 km far from port and considered outside port limits by port authorities, are currently not considered ports and consequently not considered as port of calls. A specific UN/LOCODE does not exist for them as far as we know. With the newly inserted definitions, it is not clear if they should be considered or not. It appears that the definition of offshore facilities outside port areas but permanently connected to a port is not well defined and could be subjective. There should be a clear guidance on the definition of permanent connection to a port without room for different interpretations. This generates the following question indicatively, could we consider an FSRU as permanently connected to a port and under which conditions (commercial agreements, type of mooring and pipeline connection, etc.)?
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