The European Boating Association (EBA) takes a keen interest in the European Commission’s work in protecting the marine environment, which is to the general advantage of the recreational boating community.
We are broadly supportive of the intent of the proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on port reception facilities for the delivery of waste from ships, repealing Directive 2000/59/EC and amending Directive 2009/16/EC and Directive 2010/65/EU. However, given that the definition of “ship” in the proposed Port Waste Reception Facilities Directive includes recreational craft of any size, the EBA is concerned that the definition of “port” in the proposed Directive is unreasonably wide and would have unintended adverse consequences for the recreational boating community.
The EBA considers it unreasonable to expect a private water-front house that happens to have a jetty or pontoon on the premises to implement the proposed Directive. Similarly the EBA believes that the myriad small facilities for small recreational boats throughout the European Union that do not have a harbour authority, a harbour master and/or a regulatory jurisdiction should not be within the scope of the Directive.
The EBA believes that it is the definitions of ‘port’ and ‘ship’ in the Directive which make the scope of the Directive is unreasonably wide. The definition of a ‘port’ should be altered to indicate that a port is a place or a geographical area where there is a port or harbour authority with legal jurisdiction, to prevent unintended adverse consequences for the recreational boating community.