Here are abstracts from the open letter of Russian Association of Marine and River Bunker Suppliers to RF Prime Minister Vladimir Putin:
Russian Association of Marine and River Bunker Suppliers is extremely worried with the consequences of such an ill-considered order ban for operation of single-hull bunkering tankers within internal waters of the Russian Federation. Formally the order was issued in compliance with the Rule 21 of Annex I to MARPOL Convention prohibiting the use of single-hull tankers for international transportation of heavy oil (including heavy fuel oil). Clause 7.1 of the above Rule says the state is to decide if such vessels are to be used within the state’s internal waters. However, actually the ban was caused by last year disaster in the Kerch Strait when thousands tonnes of heavy fuel oil spilled during the heavy storm. Only one of four vessels, which sank in the Strait fell under Rule 21 of Annex I to MARPOL Convention. Actually it was a double-hull vessel which proves that oil spill was caused by the storm and negligence of the officials rather than by vessel design.
According to statistics oil spill are mainly caused by a so-called human factor today.
Environmental safety requirements are the strictest for Russian bunkering industry as compared with other countries today.
Meanwhile the above ban is to cause a full stop of Russian bunkering industry, which is one of the most significant segments in servicing international vessels. As of today, bunker sales in Russia make some 6 million tonnes per year with annual turnover amounting to RUR 75 billion. The market’s growth rates make some 5-10 % per year.
The ban will result in loss of positions won by Russian bunkering companies in competiotion with the ports of Turkey, Ukraine, Baltic states and Ukraine.
Russian bunkering companies understand the problem and see reasonability of the bunkering fleet modernization but they believe it is a gradual process which is to take 3-5 years.
Now, therefore we think it is necessary to lift the ban for operation of single-hull tankers in the RF internal waters in order to protect Russian economic interests and to ensure normal shipping in Russian ports.
We also think a work group should be set up for the development of measures aimed at optimal solution of safety issues and renovation of Russia’s tanker fleet.”