Summary of Regulatory Impact Analysis (RIA)
Department/Office:
D/Transport, Tourism & Sport
Maritime Transport Division
Stage:
Draft for consultation
Title of Legislation:
Proposal for a REGULATION OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL establishing
a framework on market access to port services and
financial transparency of ports.
Date:
July 2013
Related Publications:
1) Proposed Regulation
2) Executive Summary of Commission Impact Assessment
3) Commission Impact Assessment
4) Commission Communication: Ports - An Engine for Growth
Available to view or download at:
Through links above or else via:
http://ec.europa.eu/transport/modes/maritime/news/ports_en.htm
Contact for enquiries: Garret Doocey
Email: [email protected]
This RIA has been prepared for consultative purposes to illustrate the Irish context to the
current proposed EU Regulation and to inform Ireland’s negotiating position on the
proposal. The policy option is therefore taken as the published European Commission
Regulation proposal [Com 2013/296 or COD 2013/0157]. There were four options
considered by the Commission and detailed in its Impact Assessment. These are listed
below:
PP1) Horizontal Instruments and Transparency;
PP2) Regulated Competition;
PP2a) Regulated Competition and Port Autonomy;
PP3) Full Competition and Port Autonomy.
For the purposes of this consultative RIA only Option PP2a is discussed in detail as it is
that option which was adopted by the Commission.
OPTION PP2a In an Irish Context
COSTS
BENEFITS
IMPACTS
PP2a Minor administrative Introduction of formal Relatively
minor
costs.
consultations between port administrative
changes
authorities
and required.
users/stakeholders.
Regulatory oversight of
Ensures
ongoing what appears to be
competition in the sector.
effectively
functioning
marketplace.
1
SECTION 2: Description of Policy Context and Objectives
2.1 Background to the Proposal
2.1.1 The proposed Regulation is essentially the third attempt to legislate in the area of
port services at European level. In 2001 the European Commission (‘the Commission’)
proposed a Directive on Market Access to Port Services which was eventually rejected by
the European Parliament in 2003 and then withdrawn by the Commission. A second
proposed Directive was published in 2004 but that Directive was again rejected by the
European Parliament in 2006.
2.1.2 One significant difference between this proposed Regulation and the two previous
attempts to legislate in the area, is the fact that it will not apply to cargo-handling and/or
passenger services. Those services will instead be addressed through a new Social
Dialogue Committee for Ports to be established in June 2013 and through the separate
proposal for a Directive on the award of concessions, which will apply to ports.
2.1.3 Since that second rejection in 2006 the Commission engaged in a wide-ranging
review of the ports sector and associated services. In 2007 it published a Communication
on a European Ports Policy (COM 2007/616) which identified challenges including the
need to improve port performance and hinterland connections, to modernise ports while
respecting the environment, the lack of transparency in the use of public funding, market
access restrictions and issues relating to the organisation of port labour. The
Communication recommended a number of horizontal instruments and other nonlegislative measures to tackle these challenges. While a number of measures were
initiated, the Commission states that most of the challenges identified in 2007 remain
today and must be addressed through a combination of the proposed Regulation and other
measures contained within the accompanying Communication (see 2.1.8 below).
2.2 The proposed Regulation
2.2.1 The proposed Regulation will automatically apply to all ports within the TEN-T
core and comprehensive networks. Member States are free to apply the Regulation to
other ports if they wish.
2.2.2 There are two major ‘themes’ to the proposed Regulation –
1) Modernisation of port services and operations
-
Clarify and facilitate access to the port services market
-
Prevent market abuse by designated port service providers
-
To ensure consultation between ports and port users on the main decisions
which affect the functioning of the port in all TEN-T Ports by the
implementation date of the initiative.
‘Port services’ covers bunkering, dredging, mooring, port waste reception
facilities, pilotage and towage.
2
The core objective in this area is to allow for an open market in providing port
services.
However, the proposed Regulation does allow for a limitation on the numbers of
service providers to be imposed by port authorities through:
A) Limiting the number of providers for a particular port service due to
constraints on the availability of land within a port or public service
obligations. However, in these instances they are obliged to provide a
clear definition of the reason to limit access to the market.
B) Limiting the number of providers for a particular port service due to
Public Service Obligations imposed upon the authority.
Any decision to limit the number of port service providers must be published
by the port authority at six months in advance giving justification and an
opportunity to comment within a reasonable period. If a port authority
provides a port service itself the Member State may entrust the decision
limiting the number of providers to an authority which is independent from
the port authority. If the decision rests with the port authority then the
minimum number of providers cannot be less than two.
Member States may decide to impose Public Service Obligations in order to
ensure:
A) Service availability at all times;
B) Service availability to all parties;
C) Service affordability for certain categories of users.
The Member State will designate the ‘competent authority’ to impose such
Public Service Obligations in their State; the port authority may be that
‘competent authority’. If the ‘competent authority’ decides to impose Public
Service Obligations in all covered ports in the State, it shall inform the
Commission.
The proposed Regulation also provides for port authorities to set minimum
requirements which any port service provider must satisfy in order to operate
within the port (e.g. professional qualifications/compliance with maritime safety
or environmental requirements), although any such requirement imposed must be
transparent, non-discriminatory, objective and relevant to the port service
concerned.
2) Creation of framework conditions which attract investments in ports
-
Ensure transparency in the financial relations between public authorities, port
authorities and port service providers in all TEN-T ports by the
implementation date of the initiative.
3
-
Ensure that all TEN-T port authorities are free to autonomously set their port
infrastructure charges by the implementation date of the initiative, with the
possibility of environmental modulation of these charges.
The proposed Regulation distinguishes between ‘port service charges’ (a charge
imposed for provision of one of the defined services) and ‘port infrastructure
charges’ (a charge imposed by a port authority for the use of the port). ‘Port
infrastructure charges’ may be varied in accordance with commercial practices
(e.g. frequent users of the port) or to promote environmentally friendly practices
(e.g. use of certain fuels). Any rules regarding such variation must be relevant,
objective, transparent and non-discriminatory. The Commission has the power
through delegated acts to provide for common classifications of vessels, fuels and
types of operations according to which ‘port infrastructure charges’ can vary and
to provide for common charging principles for ‘port infrastructure charges’.
2.2.3 The proposed Regulation also requires that port authorities establish a ‘Port Users
Advisory Committee’ which must be consulted annually prior to the setting of port
infrastructure charges and port service charges. There is also a requirement that port
authorities regularly consult other stakeholders such as cargo owners, port service
providers, land transport operators, operators of vessels etc. on issues relating to:
a) The proper coordination of port services within the port;
b) Measures to improve connections with the hinterland (including measures to
develop and improve the efficiency of rail and inland waterway connections);
c) The efficiency of the administrative procedures within the port (including
possible measures to simplify them)
2.2.4 The proposed Regulation requires Member States to ensure an ‘independent
supervisory body’ monitors and supervises the application of the Regulation. The body
may be an existing body. Where Member States own or control port authorities then the
Member State must ensure an ‘effective structural separation between the functions
relating to the supervision and monitoring of this Regulation and the activities associated
with that ownership or control.’ The body will handle complaints lodged by any party in
relation to the proposed Regulation. The Body shall have the right to require port
authorities, port service providers and port users to submit information as required to
ensure monitoring and supervision of the proposed Regulation. The decision of the Body
shall have binding effects without prejudice to judicial review.
2.2.5 Any port service contract (i.e. a contract awarded under restricted market access
conditions) concluded before the date of adoption of the proposed Regulation will
continue to be valid until their date of expiry, providing the original award of contract
was made in an open, transparent and non-discriminatory manner (i.e. through public
tender). Other port service contracts will continue to be valid until expiration or the 1 July
2025 whichever is the earlier.
2.2.6 The proposed Regulation shall apply with effect from 1 July 2015
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2.2.7 The Commission has additionally published a Communication (COM 2013/295)
entitled ‘Ports: an engine for growth’. The Communication provides a policy framework
for the proposed Regulation and also includes within its eight listed actions a number of
non-legislative ‘soft-measures’ designed to support the legislative measures within the
Regulation. The legislative and non-legislative measures are designed to:
Connect ports to the trans-European network;
Modernise port services;
Attract investment to ports;
Promote the social dialogue;
Raise the environmental profile of ports; and
Encourage innovation.
2.3 The Irish context
2.3.1 The Regulation will automatically apply to all ports within the TEN-T core and
comprehensive networks. In Ireland the core network ports are Dublin Port Company, the
Port of Cork Company and Shannon Foynes Port Company while the comprehensive port
network is comprised of the Port of Waterford Company and Rosslare Europort. Together
these five ports handled 87% of all commercial traffic at Irish ports in 20121.
2.3.2 The Regulation may also apply to Drogheda Port Company and Dún Laoghaire
Harbour Company as during negotiations of the revised TEN-T Regulation Ireland
proposed that all existing ports in the Greater Dublin Area (Dublin, Dún Laoghaire and
Drogheda) be included within the Dublin ‘core’ port. This position was deemed
appropriate to provide maximum flexibility as regards any future decisions regarding
major port capacity development within the region and mirrors the currently applicable
Regional Planning Guidelines for the area. Neither Company would in itself satisfy the
qualifying criteria for inclusion within either the ‘core’ or ‘comprehensive’ networks.
National Ports Policy designates both ports as ‘Ports of Regional Significance’ and
recommends their transfer to appropriate local authority led governance structures.
2.3.3 The core objective of the proposed Regulation in this area is to allow for an open
market in providing port services. In terms of the first major ‘theme’ of the proposed
Regulation – Modernisation of port services and operations – the Irish ports sector largely
satisfies the requirements of the Regulation. The port services market in Ireland is largely
open and competitive with primarily private sector providers operating at all ports.
1
CSO (2013), Statistics of Port Traffic 2012
5
Table 1 – Limitations imposed by port companies on number of service providers?
Port
Bunkering
Dredging
Mooring
Waste
Pilotage Towage
Dublin
None
None
None
None
Yes
None
Cork
None
None*
None
None*
Yes
None
Shannon
None
None
None*
None*
Yes
None
W/ford
None
None
None
Yes
Yes
None
Rosslare
None
None*
None*
None
N/A
N/A
2.3.4 As can be seen in Table 1, the Irish ports do not generally impose formal
restrictions on the number of service providers for the covered services (see 2.3.5 below
re pilotage as an exception). However, there are a number of ports that have what might
be described as an ‘informal’ restriction in place due to space constraints etc. (marked
with * in table) and the Port of Waterford Company formally restricts the number of port
waste service providers for similar reasons. The proposed Regulation allows for such
restrictions but requires the award of any port service contract in such circumstances to
be open to all interested parties, non-discriminatory and transparent. All the ports above
award such contracts via an open tendering process as regulated by relevant procurement
guidelines and legislation.
Q1: Will the proposed Regulation’s requirements impact upon how port services
are provided in Irish ports? If so, in what way and will that impact be positive,
negative or neutral?
2.3.5 Of the six covered services referred to section 2.2.2, only one – pilotage – has an
across the board ‘restriction’ in the relevant Irish ports (Rosslare is an exception as
pilotage is not required). The Harbours Acts 1996 – 2009 require relevant port companies
to provide pilotage within their statutory pilotage district through employing pilots or
licensing individuals to act as pilots. The proposed Regulation does however provide for
exemptions on the basis of Public Service Obligations. The interplay between this Irish
statutory requirement and the proposed Regulation will require examination but as noted
in the Commission’s ‘Study on Pilotage Exemption Certificates’2, a statutory obligation
to provides pilotage services is common across various Member States and the issue will
therefore be a shared one across different countries.
2.3.5
of the
ports impose
certain minimum
requirements
at leastthe
one
Q2: All
Does
the relevant
currentIrish
statutory
arrangement
governing
pilotage fitforwithin
of
the covered
services either
throughIftheir
or through
proposed
Regulation’s
framework?
not, own
whatspecified
changes requirements
might be required
to
ensuring
compliance
with
relevant
generally
applicable
requirements.
ensure compliance with the proposed Regulation?
2.3.6 In terms of the second major ‘theme’ of the proposed Regulation, Irish ports again
largely comply with the requirements of the Regulation. There are three principles
underpinning the proposed Regulation’s actions in this area:
1) Financial transparency between public authorities and port authorities;
2) Autonomy of port authorities to set their own charges for the use of the port;
and
2
http://ec.europa.eu/transport/modes/maritime/studies/doc/2012-09-18-pec.pdf
6
3) A requirement that the charges imposed for the provision of those port
services for which a limitation on the number of providers has been imposed,
or for which the port authority itself provides the service, are set in a
transparent and non-discriminatory manner.
2.3.7 Principle 1 above is basically achieved through extending the application of the
principles of Commission Directive 2006/111/EC (transparency of financial relations
between Member States and public undertakings etc.) to all TEN-T ports through the
means of this new Regulation. The Regulation will also require port authorities’ annual
accounts reflect any public funds received and where a port authority receives public
funds and provides a port service itself, that it shall keep the accounts of each port service
activity separate from the accounts of its other activities.
2.3.8 Currently within the Irish commercial ports sector, the Commission Directive
2006/111/EC only applies to Dublin Port Company as that particular Directive’s
application is restricted to bodies whose turnover exceeds €40m in the last two applicable
financial periods. All of the covered Irish ports are established, operate and financially
report on the same statutory basis as Dublin Port Company except for Rosslare Europort,
which is effectively a business unit of Iarnród Éireann. It is not expected that the
Regulation’s requirements in this area will have any significant impact on Irish ports;
however, there may be some implications for Iarnród Éireann / Rosslare Europort. As a
general comment on the area of State funding in the sector, National Ports Policy is clear
that the commercial ports sector will not receive any Exchequer funding whatsoever and
all operations must be funded on a commercial basis.
Q3: Are the proposals in respect of the transparency of financial relations between
State and port authority likely to impact upon Irish ports? If so, in what way?
2.3.9 In relation to the separate recording of accounts related to port service provision by
a port authority, all covered Irish ports bar Rosslare provide pilotage services through
employing or licensing pilots. Additionally, Dublin Port Company provides towage
services and both Shannon Foynes Port Company and Rosslare Europort provide
mooring services. All of the ports record such information in internal management
accounts and Shannon Foynes publishes separate pilotage accounts annually and records
mooring revenues in the company’s published annual accounts. It is not expected
therefore that this requirement will have a significant impact in an Irish context.
2.3.9 The core objective of Principle 2 above is of little relevance to Irish ports as they
are solely responsible for the setting of charges relating to the use of their particular port.
The sector itself, and port users generally, may however have a view on the proposed
power of the Commission to establish common classifications of vessels, fuels and types
of operations according to which port charges may vary in the future and also to allow the
Commission establish common charging principles. Additionally, the proposed
Regulation will require the port authority to inform port users about the structure and
criteria used to determine charges imposed in a port which may not be a feature of the
current commercial environment.
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Q4: Are the proposals in respect of charging likely to impact upon Irish
ports/shipping? If so, in what way?
2.3.10 Principle 3 above would appear at this stage to have little practical relevance in an
Irish context except potentially in the area of pilotage.
2.3.11 Section 2.2.3 refers to the proposed Regulation’s requirements that a formal Port
Users’ Advisory Committee be established in ports and additionally that port authorities
must consult with various stakeholders on certain matters. Some covered Irish ports do
maintain a port users’ committee although only Shannon Foynes reports that it consults
its committee as regards charges, others report they have regular informal consultations
which customers. This proposal will therefore impact upon how the majority of covered
Irish ports operate.
Q5: Are the proposals referred to in s2.3.10 and 2.3.11 beneficial or not in an Irish
context? Are there alternative options to be considered?
2.3.12 The proposed Regulation requires Member States establish an ‘independent
supervisory body’ to monitor and supervise the application of the Regulation. Previous
studies in Ireland (High Level Review of the State Commercial Ports in 2003 and the
previous Ports Policy Statement 2005) concluded that the costs associated with the
establishment of a port sector specific regulator would be prohibitive. However, the scope
of the proposed Regulation and the supervisory responsibility would appear in many
respects to complement or duplicate existing powers under Competition law.
SECTION 3: Identification and Description of Options
There were four potential options identified by the Commission and detailed in its Impact
Assessment. The descriptions below are taken directly from the Executive Summary of
the Commission’s Impact Assessment.
3.1 Option PP1 Horizontal Instruments and Transparency
3.1.1 This option combines the use of horizontal instruments, a soft measure on market
access and legally binding provisions on financial transparency, intra-port coordination
and port infrastructure access charges. The soft measure is a non-binding Commission
Communication which explains the Treaty on the Functioning of the European Union
rules on non-discrimination and the future Directive on concession.
3.2 Option PP2 Regulated Competition
3.2.1 This option introduces the freedom to provide services to the provision of port
services. This freedom can be limited if necessary, based on objective and transparent
reasons related to the lack of space or reasons of public interest. When limiting the
freedom, the public or port authority would have to enter into a contractual arrangement
8
with a port service provider via an open tendering procedure, except in duly justified
cases.
3.2.2 Transparency is enforced in those cases where public funding is involved in order to
be able to track possible distortive state aids and cross subsidies between port services. If
the service is provided by an in-house operator or another operator with an exclusive
right, a confinement obligation ensures reciprocity in the first case and price regulatory
oversight avoid abuses in both cases. The charging for using the port infrastructure is
done transparently and based on cost. A port users’ committee helps to orient the port
activities more towards the users and clients of the port.
3.3 Option PP2a Regulated Competition and Port Autonomy
3.3.1 This option consists of Option PP2 above with the following variations:
An obligation to have recourse to open tendering in the event of space restrictions
or public service obligations applies not only to new contracts but also to
substantial changes to existing contracts.
The regulatory oversight of service providers with exclusive rights applies only to
the markets which have not been granted through an open tendering.
Each port is given the right to set itself the structure and level of port
infrastructure charges provided that the charging policy remains transparent. The
initiative also encourages a differentiation according to the environmental
performance of ships or fuels.
3.4 Option PP3 Full Competition and Port Autonomy
3.4.1 This builds on Option PP2a by additionally requiring at least two competing and
independent operators for each port service where the number fo operators is limited as a
result of space constraints. There is also a functional/legal separation. To ensure that the
port keeps functioning, the central coordination role of the port authority is strengthened.
Preferred Option: Option PP2a Regulated Competition and Port Autonomy
The Commission’s preferred option is PP2a as it will generate savings in port cost of the
order of €1billion per year across the EU. It will also induce additional short-sea shipping
traffic of around 13.3 billion tonne-kilometres (an increase of up to 6.5% on a number of
routes). This will lead to increased port activities, which will create direct and indirect
port-related jobs.
Q6: Is the Commission’s preferred option the most appropriate in a) the Irish
context and b) the European context? If not what other options should be
followed?
SECTION 4: Analysis of Costs, Benefits and Impacts
4.1 This RIA been prepared in order to illustrate the Irish context to the current proposed
EU Regulation and to inform Ireland’s negotiating position on the proposal. The policy
9
option under primary consideration is therefore taken as the published European
Commission Regulation proposal [Com 2013/296 or COD 2013/0157]. Analysis of the
other options considered by the Commission, and referred to in section 3, can be found in
their own Impact Assessment.
4.2 Impacts
4.2.1 A preliminary assessment of the proposed Regulation’s impact in the Irish
commercial ports sector is that will have little discernible impact in how port services are
provided in our ports or on the level of competition that exists in the provision of these
services. This is based on Departmental analysis of answers provided by the port
companies in response to a short questionnaire circulated in late June 2013 following the
publication of the proposed Regulation. As referred in National Ports Policy3, a number
of studies completed since corporatization of the sector in the late 1990s have all referred
positively to the competitive conditions in the sector. The Competition Authority is
currently undertaking a market study of the sector and the conclusions of that study will
inform future Government policy on competition in the sector. The views of the
Authority will also be sought on the implications of the proposed Regulation.
4.2.2 The principal impacts would therefore appear to relate to changes in administrative
practices in certain areas rather than structural changes to the market itself. These
administrative changes include the requirement that Government nominate an
independent supervisory body to monitor and enforce application of the proposed
Regulation. There might also be an impact in the area of pilotage as this a service
organized by ports on the basis of a statutory requirement imposed by Government.
4.2.3 The impact on the ports sector would appear to primarily relate to the obligation to
establish port users’ advisory committees and associated obligations to consult annually
with these committees on port charges.
4.2.4 The principal impact in an Irish context would be the introduction of port sector
specific legislative and regulatory oversight of the provision of port services.
Q7: Are there any unidentified impacts which require consideration? If so, please
detail.
4.3 Costs
4.3.1 The designation of an independent supervisory body to monitor and supervise the
application of the Regulation might give rise to some additional administrative cost at a
Government level.
4.3.2 Relatively minor administrative costs might arise to port companies (and potentially
port service providers and port users) from the formal establishment of a Port Users’
Advisory Committee. As an example, the Commission’s Impact Assessment quotes a
3
See section 2.3.1 of National Ports Policy
10
cost for administrative duties of €250 per day for authorities and €190 per day for private
companies4. Based on the Commission’s assumptions as per time commitment there
might therefore be an assumed cumulative cost in Ireland of approximately €33,000 per
annum in respect of this measure. Of course, such committees are already established in
two Irish ports – Shannon Foynes and Port of Waterford – and no additional costs would
therefore arise, but the other ports do not currently have established committees and
handle relations with port users on a more informal basis.
4.3.3 At this stage it is not expected that the rules regarding financial transparency will
impact upon Irish ports, although there might be some implications for Rosslare Europort
and how its financial performance is currently recorded within Iarnród Éireann.
Q8: Are there any unidentified costs which require consideration? If so, please
detail and if possible provide cost estimations.
4.4 Benefits
4.4.1 The tangible national level benefits from the introduction of the proposed
Regulation would not appear to be very substantive. However, that it is primarily due to
the fact that the Irish commercial ports sector already fulfills the principles that the
proposed Regulation espouses and there would not therefore appear to be much national
level ‘added-value’ to the proposals.
4.4.2 Port users may benefit from the requirement that all ports establish formal Port
Users’ Advisory Committees and consult annually with the committee as regards the
rates of port charges. Other stakeholders, such as cargo owners and land transport
operators, may benefit from the requirement that port authorities regularly consult on
certain matters relating to the port.
4.4.3 Another benefit from the proposed Regulation would be the legislative requirement
that the current competitive conditions in the Irish marketplace exist as a basic principle
into the future.
Q9: Are there any unidentified benefits which require consideration? If so, please
detail.
SECTION 5: Consultation
5.1 This RIA has been drafted for consultative purposes in order to illustrate the Irish
context to the current proposed EU Regulation and to inform Ireland’s negotiating
position on the proposal.
5.2 At a European level, the proposed Regulation has been subject to extensive
consultation and the Commission organised a number of EU wide consultations which
4
Annex IX of the Commission’s Impact Assessment
11
Irish bodies and organisations participated in and which informed the overall
development of the Regulation.
5.3 Upon publication of the proposed Regulation the Department circulated a short
questionnaire to the covered Irish ports in order to inform a preliminary assessment of the
potential impact of the proposals. Furthermore the Department has been copied with the
initial view of the Irish Ports Association as submitted to their European representative
body, the European Sea Ports Organisation, and has received a formal position from the
Board of Dublin Port Company.
5.4 This draft consultative RIA will be published on the Departmental website and
specific notification circulated to the bodies below in order to allow interested
stakeholders consider the proposed Regulation and the impacts in Ireland.
Table 2 – Notification List
Competition Authority
ICTU
Irish Maritime Development Office
Port of Cork Company
Irish Exporters Association
Shannon Foynes Port Company
Irish Ports Association
Port of Waterford Company
Irish Chamber of Shipping
Rosslare Europort
Irish Ship Agents’ Association
Drogheda Port Company
Irish Port Employers’ Association
Dublin Port Company
Association of Maritime Pilots of Ireland
Dún Laoghaire Harbour Company
Institute of Chartered Shipbrokers
SECTION 6: Enforcement and Compliance
6.1 As referred in section 2.1.7, the proposed Regulation requires Member States to
ensure an independent supervisory body to monitor and supervise the application of the
Regulation. The body must be legally distinct and independent of any port authority or
port service provider. Where Member States own or control port authorities then the
Member State must ensure an ‘effective structural separation between the functions
relating to the supervision and monitoring of this Regulation and the activities associated
with that ownership or control.’
6.2 The body will handle complaints lodged by any party in relation to the proposed
Regulation. The Body shall have the right to require port authorities, port service
providers and port users to submit information as required to ensure monitoring and
supervision of the proposed Regulation. The decision of the Body shall have binding
effects without prejudice to judicial review.
Q10: Who in your view would be the most appropriate supervisory body for the
purposes of the Regulation?
SECTION 7: Review
This RIA will be reviewed and updated as required throughout the consultative process.
12
SECTION 8: Publication
As detailed in section 5 this RIA will be published on the Departmental website and
publication notified to a number of specific bodies.
Maritime Transport Division
D/Transport, Tourism and Sport
July 2013
13