The Montenegrin inspection, which is responsible for the control of foreign ships (PSC - Port State Control), does not allow cruise ships coming to Kotor to use exhaust gas purification systems (EGCS), if those ships in our waters use fuel with a sulfur content of less than 3,5 grams per kilogram (3,5% m/m).
This is against the practice recommended by the International Maritime Organization (IMO), as well as the rules that apply in EU countries. At the same time, the inspection allows the use of the EGSC system, i.e. the so-called scrubber with closed loop mode of operation for dirtier fuels that have more than 3,5% m/m sulfur, and there are no more cases in the cruise industry in the Mediterranean.
In its procedure, the PSC inspection refers to the "Decree on limit values of polluting substances in liquid fuels of petroleum origin" from 2017.
Due to this behavior of the PSC inspection, the deputy director of the International Association of Cruise Companies (CLIA) for ports, destinations and costs Nikos Mertzanidis sent a letter to the Minister of Maritime Affairs in August Filip Radulović, the management of Port of Kotor and the mayor of Kotor Vladimir Jokić, asking to explain to him the "arbitrary decision of the PSC inspector in Kotor to prohibit the use of exhaust gas purification systems on ships in Boka Kotorska". Mertzanidis asked for a meeting with Radulović.
According to unofficial information from "Vijesti", which had access to this letter, the Ministry of Maritime Affairs has not yet responded to the remarks from Brussels, where CLIA is headquartered, as well as to Mertzanidis's warning that this behavior of the PSC inspection is not in accordance with the standards for the prevention of environmental pollution. environment from ships prescribed by the IMO.
Radulović's position, as told to "Vijesta" in the Ministry of Maritime Affairs, is that the positive regulations must be respected, but that the minister is open to revising them if it is significant for tourism.
"Montenegro is a valued destination for the international cruise industry and enjoys great economic benefits from cruise tourism. Especially the city of Kotor, as a cultural and historical attraction of the Adriatic that enjoys UNESCO protection, is an important part of the cruise itinerary in the Eastern Mediterranean. In that region, Montenegro has a significant and strong role, with more than 615.000 passengers who will visit its ports during the docking of 432 cruise ships in the period from March to November this year. At this moment, for the next year, 439 cruise ships are scheduled to enter Montenegrin ports, and it is expected that they will bring 655.000 passengers", said Mertzanidis.
He recalled in the letter that EGCS systems for purifying exhaust gases from marine engines are "an acceptable means of meeting environmental standards, recognized by the International Maritime Organization and the European Union".
EGSC systems or scrubbers with so-called with a closed loop system, they use seawater to chemically react with exhaust gases to drastically reduce the sulfur content in those gases, before they are released into the atmosphere, and in order for the ships to meet the strict standards for reducing the emission of sulfur oxides, which are defined by Annex VI of the international MARPOL convention, and also transferred in the current EU Sulfur Directive. When working in closed loop mode, the scrubbers do not discharge the water that was used for exhaust gas purification into the sea, and such a regulation also applies in Montenegro.
Mertzanidis also states that in the "Regulation on limit values of polluting substances in liquid fuels of petroleum origin", there are no grounds that would justify the prohibition of using the EGSC system in closed loop mode" and asked Radulović to "send a circular letter to the PSC inspectors that would support the correct and the precise interpretation of the previously mentioned Regulation, in accordance with the relevant EU legislation".
The Ministry of Maritime Affairs and Transport told "Vijesta" regarding the letter they received that the current regulations clearly state how and under what conditions the use of scrubbers in the bay is allowed.
"The position of the minister is that positive legal regulations must be respected, but he is open to revising the existing regulations if it is of essential importance for tourism, without jeopardizing the current state of protection of the seabed and its surroundings," said the Ministry of Transport.
They said that based on the provisions of Article 18 of the Regulation "all ships, regardless of whose flag they fly, can use methods to reduce emissions of polluting substances in the air in Montenegrin ports, territorial sea and exclusive economic zone if they achieve a constant reduction of sulfur emissions (IV) of oxides that is at least equivalent to the emissions during the use of marine fuels from Art. 8, 13 and 14 of this Regulation."
In those articles, it is defined that marine diesel fuel, i.e. marine gas oil, can be put into circulation in Montenegro if the sulfur content in them does not exceed 1,5% m/m, i.e. 0,1% m/m. It is also prescribed that "in the territorial waters of Montenegro and the exclusive economic zone, marine fuel can be used, if the sulfur content does not exceed 3,5% m/m, except for marine diesel fuel and marine gas oil."
When asked what is the basis for the PSC inspection to prohibit the use of scrubbers if ships use fuel that contains less than 3,5% but more than 0,1% or 1,5% sulfur, the Ministry explained that the inspection does so "referring to Article 13, paragraph 2, indent 3 of the Regulation in question - ships that use methods to reduce air pollutant emissions in closed systems can only do so if they use fuel with a sulfur content of over 3,5% m/m."
"According to the information we received from the pilot of Port of Kotor, as well as the knowledge we have from our inspectors, all ships that sail into the Bay of Kotor burn oil with 1,5% to 2,5% sulfur, which is below the prescribed content of 3,5 .13%, so the exemption in Article 2 paragraph 3 indent 0,1 cannot be applied, but ships must directly use fuel whose sulfur content does not exceed XNUMX%", said the Ministry of Maritime Affairs.
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