Here’s a useful article on Marine Insight website that gives some more information about the legalities of the STS process.
Interestingly it states:
“A ship to ship transfer becomes very economical as ship does not have to berth at the jetty, especially for huge oil tankers, which removes the port berthing charges and also cut short the time for berthing and mooring. But all these comes at a cost of high environmental pollution and fire risk as chances of leakage in operation is always there in open sea when ship is not moored or it is moving.”
That’s really the crux of what we have been saying all along – it’s cheaper to do it at sea but the risks are higher. It’s maybe sounding like a broken record, but its important. The CFPA are trying to do this on the cheap at the expenses of the environment. Don’t let them do it.