The document outlines the need for a new, simplified Inland Vessels Act to promote use of waterways for transportation and proposes several recommendations including establishing a central nodal agency, enabling pan-India operations, and ensuring state rules are consistent and do not hamper inter-state movement. The goal is to increase use of IWT which is cheaper and more environmentally friendly compared to road and rail transportation.
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
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5. SEA TRUCK – shallow draft RoRo pax
tendered by MMB for Mumbai east
waters – join in pre bid meeting 6 April
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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
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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
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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
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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
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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.
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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
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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
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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
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)
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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
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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 !!!
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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
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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
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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
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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%)
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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…
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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
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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.
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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
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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
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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
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