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1
VISIONARY
"That's been one of my mantras – focus and
simplicity. Simple can be harder than complex:
You have to work hard to get your thinking clean to
make it simple. But it's worth it in the end because
once you get there, you can move mountains” KIS
– keep it simple
Steve Jobs
We must make shipping lean simple and
practical
2
PICTURES
 Setting stage for the topic to make IWT happen
3
SEA TRUCK – shallow draft RoRo pax
tendered by MMB for Mumbai east
waters – join in pre bid meeting 6 April
5
Suction Dredger enable river drafts
Suction Dredger Made in India
– Make in India
Typical example of appropriate technology and make in India solution suitable
for dredging in alluvial rivers and free flowing clay and sandy back waters
BACKGROUND
 The Government on taking office in June 2014 quickly
moved on a policy matter to review / repeal all old
legislation especially from the colonial past
 IV Act, 1917 as amended 2007 is one such Act that is under
comprehensive revision
 IWT has here to before been a neglected sector – water
never featured as important for navigation – PURE POLICS
OF VOTE BANK
 2007 amendment mainly introduced overdue pollution
prevention and insurance angle and attempted to increase
scope of I V limits based errorneous criterion incuding
weather as function of significant wave height
 RHINE, SEVERN took 100 years to develop, we have lost 70
years in recognising water is for navigation toooooooo
7
FOCUS
 To increase freight transport in India by water so as to
reap the benefits of cheaper, environment friendly and
safer mode of transport thereby contributing to
reduction in transport carbon foot print and logistic
costs which in India are one of the highest in the world
 Seamless transfer of freight between sea going coastal
and IWT bringing end user closer to water land
interface – SAGARMALA – 15000 cr allocation to
Mahrashtra alone ; 49000 cr from WB for NW t
Kolkata to Varanasi by 2019 !!!!
 Japan, China, EU have thousands of Inland vessels
often family owned just like trucking industry here
8
Median freight differential
shock!!! Although water transport should be
30 % cheaper by consideration of zero
friction in fluid alone
 KPMG study demonstrated over a range of cargoes and
routes that there is a median freight differential of Rs.
500 per ton per km
9
 The Act was designed to just regulate country crafts not as
part of infrastructure necessity as road rail were needed to
govern the country
 The Act mainly required defining I V limits, some basics
of vessel size, capacity and its operation limits
 To state basic crew requirement and terms prevalent then
 Requiring local governments to frame required rules
which many did not or keep in step post independence
 However, IWAI Model rules cannot be mixed in new Act
nor allow some sitting here to overlook this sector
 Some amongst us would prefer continuing status quo –
unclear IV limits, port limits, definition of sea going,
pleasure craft etc etc etc for OBVIOUS REASONS
10
NEW IV ACT
 THEREFORE AT LAST Bearing in mind structure of
Indian Constitution and enabling primary legislation
therefor, certain activities such as Ports and Inland
Vessels is a State subject
 The new IV Act has been drafted as a Central piece of
Primary Legislation of the central Government to be
implemented by respective State Government
 In addition to declared National Waterways, NW1 –
NW5, the Central Government is proposing to make
another 106 national waterways so as to bring water
interface closer to end user but is still to be reflected in
the new draft I V Act.
11
INSA COMMENTS
 New I V Act should be crisp, short and simple
 Facilitate IWT thru nodal agency – IWAI , MB / Competent
authority mandated in the Act for pan India like MV Act
 Provide for e governance
 Enabling provisions to ensure no bottlenecks in rules made
under this Act by the States so as not to hamper inter State
movement of inland vessels
 Encourage investment into IWT from hinterland
 Stipulate only minimum mandatory manning
requirements including minimum mandatory hands on
training with details of certification in the State rules
12
CMMI OBSERVATIONS
 The new Act should be short, simple and effective pan
India
 Legal processes should be as are applied in case of MV
Act
 State rules should be mandated in given time and not
less than the minimum mandatory requirement given
in the Act
 The Act should clearly state who is nodal agency –
IWAI / Jal Vikas marg authority and State Maritime
Boards / Competant authority for implementation like
RTO
13
HEAVY CAPEX IN
HUGE COSTLY…
COS…
HIGHLY
SENSITIVE TO
ENVIRONMENT
DREDGIN
G
PRESENT TREND OF OVER-COMING
“PRODUCTIVITY”
Jal Marg Vikas Project – Decongestion of Road & Rail
Bulk/Break Bulk Cargo Carriers
Mode Carrier Type Carrying Capacity (MT)
Road Truck (Normal 10 wheeled) 16
Rail
BOXN Rail wagon (each) 62
Rail Rakes of (40 Wagons) 2200
IWT IWT Vessels 2000
1 standard 2000 DWT vessel compares to 125 Truck Loads and almost 1
complete train rake (40 rail wagons) load from existing road & Rail
infrastructure
Shallow Waterways Shipping
follows ATB concept
TUG & BARGE LINK - ATB TUG & BARGE LINK - ATB
Shallow Waterways Shipping
“PRODUCTIVITY”
1) Major Bottle-Neck
Shallow Water - Qty 900 Mt Deep Water – 90,000 Mt
Road rail only getting attention
again and again – from colonial
days, making of bridges over large
rivers of Bengal to rule India
 Over and above, road rail in India is burdened with very
little Health, Safety, Environment, Social cost,
International norms and practices.
 If this is done, road rail freight will start converging
towards coastal freight rates burdened with all of these.
 In fact, over loaded truck, over sized cargo on truck,
accidental losses, damage and theft of cargo are every day
scenes.
 Coastal ship does it so much better …………………………. 18
Ushering a step change……..
……………………Requires:
 Progressive Domestic Shipping Act to replace provisions of MS Act
and other Maritime Acts and Rules made on colonial days
 Make shipping and ports federal subject
 Expert industry infrastructure status for the greater good of the
country
 Long term Government support – YOJANAS similar to Manrega,
JNRUM, Rajiv Vikas, Food security, RTE, Free power and water
where crores are being spent with little benefit to the exchequer
 Shipping Bank which understands business of shipping, sail and
purchase (1990s subsidy to barges saw quantum jump in the fleet)
 Cabotage / reservation with affirmative action
 Creation of Maritime clusters / parks
 Government led investment (like MOD) into applied R&D
 Attract investment in India for infrastructure, manufacturing, tourism by
way of clear rules of engagement, clarity in conformity (no
retrospective changes) and generally ease of doing business for the
targeted growth of 8-10 % (create 50 million jobs per annum – Davos)
19
Ushering a step change……..
All one is asking for is:
 “Moolbhut Suvidha” to allow shipowners and operators
to perform and make profit
 Level playing field
 Measures such as second register, Choice of Classification
 Thriving Banking and Insurance facilities
 Maritime constituency to foster shipping enterprise and lobby in
force
 Sagarmala kind of concept and interlinking of rivers to reduce cost
of first and last mile
 Liberal approach to FDI, rightful share in shipping GDP, reduction
in current over regulation of Indian Coastal shipping
20
De Regulate - - IWAI - - like JG of Japan – a
local Japanese vessel 20 year old seen by NKK
and operating 500 ‘ SE of Tokyo is being found
unsuitable for service in Indian waters !!!
21
Germany prohibits movement of trucks from Fri
mid night to Monday 7 am !!! On National
Highways so RHINE becomes viable option,
dentists and corporators invest in IWT !!!!
Modality
CO2 emission (g/t-km)
Semi-trailer truck (artic)
60 – 80
Truck 10-20 tons (Local delivery)
120 – 150 big polluter
Ship 250-1000 tons
35 – 70
Ship 1000-3000 tons
30 – 55 clear winner
22
• High transport volumes, low cost, safety, efficiency, two way and low carbon
foot print
• Shallow draft Dry bulk, solid, liquid, tug bargo combo, containers, ro ro pax, car
carrier, pctc
• LAD 2.5m to 3.0 m >> 1500-2000t, capex under USD 2m
• Ideal L = 120, B=12m, good payload at 97x12 or 80x 14.5m
• ULC of 0.5 m necessary to prevent grounding and built in features to repair
propeller insitu
• Good hull form, indianised engineering, equipment, RIVER INFORMATION
SERVICE, GPS cell fone technology, recycled steel, no Class approval except if
carrying IMDG cargo
• Twin screw 2 x 750 hp KOWL, Cummins, Pilstick, double rudders behind each
propeller, robust gear box, water cooled shaft, 200 kw bow thrusters,
• Double bottom , fuel oil not in contact with outer shell, two compartment status,
scantling to suit 1.0 m significant wave height,
• Simple comfortable small crew accomodation suitable for Indian national
conditionsof equivalent industrial activity
• Construction standards meeting EU, JG specificatyions – NKK, LR, DNVGL
23
IWT – Multi Modal - Opportunities
 Water borne transport – oldest means to move cargo, people
 Shipping is life line of trade and hence of economy, second line
of defense
 Long established maritime tradition, coastline – 7500 km
 Most environment friendly, cheapest per ton km transport
system
 12 major port trusts, over 100 private / State authority ports
functioning
 Cabotage relaxed provisions, Indian industry, Director General
of Shipping.
 Some 800 mil MT of cargo is moved annually from our ports
 Coastal traffic is insignificant compared to USA, EU, Japan &
China. Just 480 vessels of 80,000 dwt; mostly more than 15
years old.
 Carrying some 100m out of total seaborne trade in ports of 6-
800m
 100 m t of river traffic to be generated NW 1- 5, Bangladesh
protocol
 Bulk solid liquid distrubution, PSU cargo – sand salt ores,
diesel, FCI, steel, ODC, tiles, ce,ent, Klinker, MSME, etc
24
In the words of IMO Secy. Gen. this is
more than ship operations only. It must
include all the activities that are vital to
support shipping. Indian MS Act
Preamble says so but is not up to date in
time. Government should do a few things
well rather than attempting to do many
and succeeding at little. Timely actions is
name of the game.
Green laws will soon cost the industry
$1000 bn by 2020 (SO2 < 3%)
25
Because of no level playing field, obsession
in continuing antiquated laws; obsession
with colonial shipping practice; customs,
immigration, crew matters, ship Registry, no
second Register, Classification
requirements; lack of shipping finance
modernization, insurance industry, shipping
lines not able to make money, very high
compliance costs, training costs, no boost
for enterprise and maritime lobby, no
political support for shipping or maritime
clusters / parks etc…
26
27
2022 more companies more ships more seafarers; business
of strong maritime constituency
 Hon’ble Minister recently visited Mississisipi waters
and hope changes are in the offing
 Roads = more traffic; ports alone not = ships
INTERNATIONAL EXAMPLES
FOR GREATER GOOD of COUNTRY
 UK SI 1993 No. 1072 giving enabling powers, and
list of provisions not applied to small commercial
vessels
 UK MGN on guidance for training and manning of
inshore craft, Boat masters’ license
 MPA all inclusive harbour craft license
 MPA Regulations 1981 defining Home trade,
Special limits
 Netherlands Maritime Directorate Act for trading
in restricted area, Manning orders, and
commercial code
29
Contd…..
 PRC Technical Regulations for the statutory survey of sea
going ship engaged in non international voyages 1999 –
void outside China
 PRC delegation of powers to - Domestic ship survey
center (RTO RC BOOK TYPE APPROACH)
 JG Class of Japan District Government Regulation for all
inclusive certificate of Nationality, periodically endorsed
 US CODE of Federal Regulations CFR 49 under Jones Act
authorizing State Governments to ISSUE ORDERS for
facilitating coastal traffic. One of the most powerful
integrated transport systems in the world.
30
WISH LIST….
 CREATE STRONG MARITIME CONSTIUENCY
CAPABLE OF BEING HEARD IN CORRIDORS OF
POWER
 PERMIT REDUCTION IN PROCEDURES FOR ISSUE
OF rsv registration, CERTIFICATES BY RO only
expediently – one all encompassing certificate of
fitness or code certificate (including ship manual)
 Issue limited use NCV COC to I V class, ex navy, army
 Facilitate INVESTMENT IN R&D, INNOVATION –
design, manning, ship building, training – by quick
decisions in recently established task force
31
Conclusion – lean (domestic)
shipping
What to do
1. Contribute meaningfully to climate change
programme with due regard to shipping
requirement in Indian context
2. Enable ships to run safely, efficiently, profitably by
of government dialogue
3. Invest in people for lean shipping initiatives
including environment awareness
4. CMMI LEAD in active participation in steering
committees on local environment
5. Do not allow use shipping as cash cow to arrest
global warming
Without shipping and seafarers half the world will
freeze, other half will starve
32
33
NEW INDIA 2022
Lets contribute
THANK YOU
Capt. S. V. Subhedar
Past President
ICC Shipping Association
Email: capt_subhedar@hotmail.com
Mobile no.: +91 9823158057
34

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Visionary Insights for Promoting Inland Water Transport in India

  • 1. 1
  • 2. VISIONARY "That's been one of my mantras – focus and simplicity. Simple can be harder than complex: You have to work hard to get your thinking clean to make it simple. But it's worth it in the end because once you get there, you can move mountains” KIS – keep it simple Steve Jobs We must make shipping lean simple and practical 2
  • 3. PICTURES  Setting stage for the topic to make IWT happen 3
  • 4.
  • 5. SEA TRUCK – shallow draft RoRo pax tendered by MMB for Mumbai east waters – join in pre bid meeting 6 April 5
  • 6. Suction Dredger enable river drafts Suction Dredger Made in India – Make in India Typical example of appropriate technology and make in India solution suitable for dredging in alluvial rivers and free flowing clay and sandy back waters
  • 7. BACKGROUND  The Government on taking office in June 2014 quickly moved on a policy matter to review / repeal all old legislation especially from the colonial past  IV Act, 1917 as amended 2007 is one such Act that is under comprehensive revision  IWT has here to before been a neglected sector – water never featured as important for navigation – PURE POLICS OF VOTE BANK  2007 amendment mainly introduced overdue pollution prevention and insurance angle and attempted to increase scope of I V limits based errorneous criterion incuding weather as function of significant wave height  RHINE, SEVERN took 100 years to develop, we have lost 70 years in recognising water is for navigation toooooooo 7
  • 8. FOCUS  To increase freight transport in India by water so as to reap the benefits of cheaper, environment friendly and safer mode of transport thereby contributing to reduction in transport carbon foot print and logistic costs which in India are one of the highest in the world  Seamless transfer of freight between sea going coastal and IWT bringing end user closer to water land interface – SAGARMALA – 15000 cr allocation to Mahrashtra alone ; 49000 cr from WB for NW t Kolkata to Varanasi by 2019 !!!!  Japan, China, EU have thousands of Inland vessels often family owned just like trucking industry here 8
  • 9. Median freight differential shock!!! Although water transport should be 30 % cheaper by consideration of zero friction in fluid alone  KPMG study demonstrated over a range of cargoes and routes that there is a median freight differential of Rs. 500 per ton per km 9
  • 10.  The Act was designed to just regulate country crafts not as part of infrastructure necessity as road rail were needed to govern the country  The Act mainly required defining I V limits, some basics of vessel size, capacity and its operation limits  To state basic crew requirement and terms prevalent then  Requiring local governments to frame required rules which many did not or keep in step post independence  However, IWAI Model rules cannot be mixed in new Act nor allow some sitting here to overlook this sector  Some amongst us would prefer continuing status quo – unclear IV limits, port limits, definition of sea going, pleasure craft etc etc etc for OBVIOUS REASONS 10
  • 11. NEW IV ACT  THEREFORE AT LAST Bearing in mind structure of Indian Constitution and enabling primary legislation therefor, certain activities such as Ports and Inland Vessels is a State subject  The new IV Act has been drafted as a Central piece of Primary Legislation of the central Government to be implemented by respective State Government  In addition to declared National Waterways, NW1 – NW5, the Central Government is proposing to make another 106 national waterways so as to bring water interface closer to end user but is still to be reflected in the new draft I V Act. 11
  • 12. INSA COMMENTS  New I V Act should be crisp, short and simple  Facilitate IWT thru nodal agency – IWAI , MB / Competent authority mandated in the Act for pan India like MV Act  Provide for e governance  Enabling provisions to ensure no bottlenecks in rules made under this Act by the States so as not to hamper inter State movement of inland vessels  Encourage investment into IWT from hinterland  Stipulate only minimum mandatory manning requirements including minimum mandatory hands on training with details of certification in the State rules 12
  • 13. CMMI OBSERVATIONS  The new Act should be short, simple and effective pan India  Legal processes should be as are applied in case of MV Act  State rules should be mandated in given time and not less than the minimum mandatory requirement given in the Act  The Act should clearly state who is nodal agency – IWAI / Jal Vikas marg authority and State Maritime Boards / Competant authority for implementation like RTO 13
  • 14. HEAVY CAPEX IN HUGE COSTLY… COS… HIGHLY SENSITIVE TO ENVIRONMENT DREDGIN G PRESENT TREND OF OVER-COMING “PRODUCTIVITY”
  • 15. Jal Marg Vikas Project – Decongestion of Road & Rail Bulk/Break Bulk Cargo Carriers Mode Carrier Type Carrying Capacity (MT) Road Truck (Normal 10 wheeled) 16 Rail BOXN Rail wagon (each) 62 Rail Rakes of (40 Wagons) 2200 IWT IWT Vessels 2000 1 standard 2000 DWT vessel compares to 125 Truck Loads and almost 1 complete train rake (40 rail wagons) load from existing road & Rail infrastructure
  • 16. Shallow Waterways Shipping follows ATB concept TUG & BARGE LINK - ATB TUG & BARGE LINK - ATB
  • 17. Shallow Waterways Shipping “PRODUCTIVITY” 1) Major Bottle-Neck Shallow Water - Qty 900 Mt Deep Water – 90,000 Mt
  • 18. Road rail only getting attention again and again – from colonial days, making of bridges over large rivers of Bengal to rule India  Over and above, road rail in India is burdened with very little Health, Safety, Environment, Social cost, International norms and practices.  If this is done, road rail freight will start converging towards coastal freight rates burdened with all of these.  In fact, over loaded truck, over sized cargo on truck, accidental losses, damage and theft of cargo are every day scenes.  Coastal ship does it so much better …………………………. 18
  • 19. Ushering a step change…….. ……………………Requires:  Progressive Domestic Shipping Act to replace provisions of MS Act and other Maritime Acts and Rules made on colonial days  Make shipping and ports federal subject  Expert industry infrastructure status for the greater good of the country  Long term Government support – YOJANAS similar to Manrega, JNRUM, Rajiv Vikas, Food security, RTE, Free power and water where crores are being spent with little benefit to the exchequer  Shipping Bank which understands business of shipping, sail and purchase (1990s subsidy to barges saw quantum jump in the fleet)  Cabotage / reservation with affirmative action  Creation of Maritime clusters / parks  Government led investment (like MOD) into applied R&D  Attract investment in India for infrastructure, manufacturing, tourism by way of clear rules of engagement, clarity in conformity (no retrospective changes) and generally ease of doing business for the targeted growth of 8-10 % (create 50 million jobs per annum – Davos) 19
  • 20. Ushering a step change…….. All one is asking for is:  “Moolbhut Suvidha” to allow shipowners and operators to perform and make profit  Level playing field  Measures such as second register, Choice of Classification  Thriving Banking and Insurance facilities  Maritime constituency to foster shipping enterprise and lobby in force  Sagarmala kind of concept and interlinking of rivers to reduce cost of first and last mile  Liberal approach to FDI, rightful share in shipping GDP, reduction in current over regulation of Indian Coastal shipping 20
  • 21. De Regulate - - IWAI - - like JG of Japan – a local Japanese vessel 20 year old seen by NKK and operating 500 ‘ SE of Tokyo is being found unsuitable for service in Indian waters !!! 21
  • 22. Germany prohibits movement of trucks from Fri mid night to Monday 7 am !!! On National Highways so RHINE becomes viable option, dentists and corporators invest in IWT !!!! Modality CO2 emission (g/t-km) Semi-trailer truck (artic) 60 – 80 Truck 10-20 tons (Local delivery) 120 – 150 big polluter Ship 250-1000 tons 35 – 70 Ship 1000-3000 tons 30 – 55 clear winner 22
  • 23. • High transport volumes, low cost, safety, efficiency, two way and low carbon foot print • Shallow draft Dry bulk, solid, liquid, tug bargo combo, containers, ro ro pax, car carrier, pctc • LAD 2.5m to 3.0 m >> 1500-2000t, capex under USD 2m • Ideal L = 120, B=12m, good payload at 97x12 or 80x 14.5m • ULC of 0.5 m necessary to prevent grounding and built in features to repair propeller insitu • Good hull form, indianised engineering, equipment, RIVER INFORMATION SERVICE, GPS cell fone technology, recycled steel, no Class approval except if carrying IMDG cargo • Twin screw 2 x 750 hp KOWL, Cummins, Pilstick, double rudders behind each propeller, robust gear box, water cooled shaft, 200 kw bow thrusters, • Double bottom , fuel oil not in contact with outer shell, two compartment status, scantling to suit 1.0 m significant wave height, • Simple comfortable small crew accomodation suitable for Indian national conditionsof equivalent industrial activity • Construction standards meeting EU, JG specificatyions – NKK, LR, DNVGL 23
  • 24. IWT – Multi Modal - Opportunities  Water borne transport – oldest means to move cargo, people  Shipping is life line of trade and hence of economy, second line of defense  Long established maritime tradition, coastline – 7500 km  Most environment friendly, cheapest per ton km transport system  12 major port trusts, over 100 private / State authority ports functioning  Cabotage relaxed provisions, Indian industry, Director General of Shipping.  Some 800 mil MT of cargo is moved annually from our ports  Coastal traffic is insignificant compared to USA, EU, Japan & China. Just 480 vessels of 80,000 dwt; mostly more than 15 years old.  Carrying some 100m out of total seaborne trade in ports of 6- 800m  100 m t of river traffic to be generated NW 1- 5, Bangladesh protocol  Bulk solid liquid distrubution, PSU cargo – sand salt ores, diesel, FCI, steel, ODC, tiles, ce,ent, Klinker, MSME, etc 24
  • 25. In the words of IMO Secy. Gen. this is more than ship operations only. It must include all the activities that are vital to support shipping. Indian MS Act Preamble says so but is not up to date in time. Government should do a few things well rather than attempting to do many and succeeding at little. Timely actions is name of the game. Green laws will soon cost the industry $1000 bn by 2020 (SO2 < 3%) 25
  • 26. Because of no level playing field, obsession in continuing antiquated laws; obsession with colonial shipping practice; customs, immigration, crew matters, ship Registry, no second Register, Classification requirements; lack of shipping finance modernization, insurance industry, shipping lines not able to make money, very high compliance costs, training costs, no boost for enterprise and maritime lobby, no political support for shipping or maritime clusters / parks etc… 26
  • 27. 27
  • 28. 2022 more companies more ships more seafarers; business of strong maritime constituency  Hon’ble Minister recently visited Mississisipi waters and hope changes are in the offing  Roads = more traffic; ports alone not = ships
  • 29. INTERNATIONAL EXAMPLES FOR GREATER GOOD of COUNTRY  UK SI 1993 No. 1072 giving enabling powers, and list of provisions not applied to small commercial vessels  UK MGN on guidance for training and manning of inshore craft, Boat masters’ license  MPA all inclusive harbour craft license  MPA Regulations 1981 defining Home trade, Special limits  Netherlands Maritime Directorate Act for trading in restricted area, Manning orders, and commercial code 29
  • 30. Contd…..  PRC Technical Regulations for the statutory survey of sea going ship engaged in non international voyages 1999 – void outside China  PRC delegation of powers to - Domestic ship survey center (RTO RC BOOK TYPE APPROACH)  JG Class of Japan District Government Regulation for all inclusive certificate of Nationality, periodically endorsed  US CODE of Federal Regulations CFR 49 under Jones Act authorizing State Governments to ISSUE ORDERS for facilitating coastal traffic. One of the most powerful integrated transport systems in the world. 30
  • 31. WISH LIST….  CREATE STRONG MARITIME CONSTIUENCY CAPABLE OF BEING HEARD IN CORRIDORS OF POWER  PERMIT REDUCTION IN PROCEDURES FOR ISSUE OF rsv registration, CERTIFICATES BY RO only expediently – one all encompassing certificate of fitness or code certificate (including ship manual)  Issue limited use NCV COC to I V class, ex navy, army  Facilitate INVESTMENT IN R&D, INNOVATION – design, manning, ship building, training – by quick decisions in recently established task force 31
  • 32. Conclusion – lean (domestic) shipping What to do 1. Contribute meaningfully to climate change programme with due regard to shipping requirement in Indian context 2. Enable ships to run safely, efficiently, profitably by of government dialogue 3. Invest in people for lean shipping initiatives including environment awareness 4. CMMI LEAD in active participation in steering committees on local environment 5. Do not allow use shipping as cash cow to arrest global warming Without shipping and seafarers half the world will freeze, other half will starve 32
  • 33. 33
  • 34. NEW INDIA 2022 Lets contribute THANK YOU Capt. S. V. Subhedar Past President ICC Shipping Association Email: capt_subhedar@hotmail.com Mobile no.: +91 9823158057 34