21 December 2018
Oil Pollution Levy Consultation
Maritime New Zealand
PO Box 25620
Sent by email:
Submission on Oil Pollution Levy
Thank you for the opportunity to make submission on the oil pollution levy mid-point review.
Coastal shipping is a vital part of New Zealand’s transport infrastructure.Recent events have shown that the coastal network is important for New Zealand economic, environmental and social welfare and vital during emergencies when road links are disabled.
New Zealand depends on coastal ships.For example:
- for delivery of important goods such as fuel oil and cement.
- for provision of a bridge for freight and passengers between Picton and Wellington.
- for moving containerised and bulk cargo around the coast
- when other modes of transport are not useable because roads or railways are broken
Central and local government decisions as well as port decisions affect the performance of the coastal network.
In the last 24 months, 4 new ships have joined the coastal fleet reflecting investments of over $150million in the New Zealand economy.
The Federation is committed to working with decision-makers to ensure that the best policy settings are in place for the benefit of all New Zealanders.We are happy to work proactively to bring sector knowledge to support the policy-making process.
The Federation remains committed to safe, secure and clean shipping.
The New Zealand Shipping Federation began in 1906 and is the key representative body for New Zealand’s coastal shippers.
Members of the Federation are:
|Coastal Bulk Shipping||www.coastalbulkshipping.co.nz||Anatoki||Bulk cargo|
|Coastal Oil Logistics (COLL)||www.coll.co.nz|
|Cook Strait ferry|
|China Navigation||www.pacship.co.nz||Aotearoa Chief||Cement|
|Spirit of Canterbury||Container cargo|
|Silver Fern Shipping||www.sfsl.co.nz||Kokako|
|StraitNZ- Bluebridge Cook Strait Ferries||www.Straitnz.co.nz||Straitsman|
|Cook Strait ferry|
The Federation supports in principle the maintenance of a high level of preparedness for oil pollution events.
Future of Oil
The Federation envisages that future fuels may be quite different to the common usage now.The immediate effect of MARPOL Annex VI is likely to be greater use being made of diesel.In the long term it may result in a widespread shift away from oil based fuels.
The distinction between the two types of oil is important.Non-persistent oil is generally understood to be oil which consists of lighter hydrocarbon factions than persistent oil.This means that non-persistent oils, when released into the environment, dissipate rapidly and evaporate and as such require little or no clean-up.The difference seems to be identified in the consultation document in respect of foreign and domestic tankers but the implications of changes in use are wider than that.
Thus the Federation believes that consideration needs to be given to the impact of changing fuel usage on pollution modelling.We would expect the changed usage also would impact on the extent of any clean-up needed and this must ultimately be reflected in the levy.
Allocation across classes of ships and types of activity
An issue of considerable contention is the way that the total levy is allocated across categories of vessels.We continue to have concerns that the model used has the effect of under-recovering from some categories of vessel that are more likely to create a pollution event.
Individual members of the Federation are likely to submit in respect of their own vessels.
The consultation document proposes three possible options, one of which is no change to the existing levy.The other two options mainly differ in that option three includes the use of tracking buoys and flurometry[AY1] to track oil spills and the effects of dispersants.
The Federation supports option two which seems like an optimal compromise between gold-plated resources and the practical limits of the levy that can be charged.It does create a significant uplift in the total levy and we are keen to ensure that the effect of this on the payers is fully understood.
Again, thank you for the opportunity to make a submission.
P O Box 10739, The Terrace, Wellington 6143
021 429 216