Mobile: 021 429 216

Submission: Oil Pollution Levy

21 December 2018

Oil Pollution Levy Consultation

Maritime New Zealand

PO Box 25620

Wellington 6146

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:

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 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


Bulk cargo

Coastal Oil Logistics (COLL)






Cook Strait ferry


Cook Strait ferry


Cook Strait ferry






China Navigation

Aotearoa Chief


Spirit of Canterbury

Container cargo

Silver Fern Shipping





StraitNZ- Bluebridge Cook Strait Ferries



Cook Strait ferry

Strait Feronia

Cook Strait ferry

General Principle

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.

Preferred model

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.

Annabel Young

Executive Director

P O Box 10739, The Terrace, Wellington 6143

021 429 216