Russian Association of Bunker Suppliers claims against modification of OSR Plan approval procedure

Self-regulated organisation Russian Association of marine and river Bunker Suppliers (RosMorRechBunker SRO) has addressed the RF State Duma’s Transport and Construction Committee and the Committee for Organisation of State Duma Operation with a claim against introduction of OSR Plan authorization requirement to replace the notification requirement without public discussion or regulatory impact assessment, the Assiciation told IAA PortNews. The address was initiated after the Duma’s Transport and Construction Committee announced its decision dated 18 October 2016 to propose passing in the second reading the draft law No 1029636-6 “On introduction of amendments into the Federal Law “On Seaports of the Russian Federation and on Introduction of Amendments into Certain Legislative Acts of the Russian Federation” and some legislative acts of the Russian Federation. The second reading of the document is scheduled for 2 November 2016. 

The Association notes a violation of the rules of statutory procedure requiring public discussion and regulatory impact assessment. The text of the draft law prepared for the second and the third reading includes the revised articles implying introduction of amendments into the Federal Law "On the Inland Sea Waters, Territorial Sea and Contiguous Zone of the Russian Federation” (No 155-FL, dated 31 July 1998) that are crucial for crude/oil product transshipment and bunkering businesses. The text discussed in the first reading did not contain the clause on replacement of the notification requirement with the authorization requirement when it comes to approval of oil spill response plans.

The Association believes that those amendments, if approved, will create new unreasonable administrative barriers and conditions for corruption. Consequently, small-size and mid-size bunker suppliers will be pushed out from the market. Moreover, operators of oil terminals that need to get their OSR plans approved will have to, apart from obtaining a state environmental approval, arrange additional exercises for their emergency response teams and obtain RF Transport Ministry’s confirmation of the proper exercise results. Besides, more time and finances will be required for such procedures.