Videotel and Maritime Training Services Work Together to Simplify US Port State Control

Despite the crucial importance of Port State Control to the wellbeing of the seafarer, the vessel and the environment, it is often viewed as a necessary evil by many seafarers. Yet a knowledge of policies and procedures, and a properly prepared ship and crew, can ensure a satisfactory outcome for all parties.

To address this issue Videotel, the world’s largest multi-media producer of high quality maritime safety training software and US-based Maritime Training Services (MTS) who produce and distribute maritime training materials that address key safety, regulatory, and operational issues facing the industry, have combined their joint expertise to produce a new training programme on US Port State Control.

The concept for the creation of the new programme was inspired by personal experience. Matt Gasparich, Managing Director at Maritime Training Services says, “Recently our film crew rode from Vancouver to Seattle on board a container ship and personally experienced the US Port State process. We compared it with our original programme produced in 1996 and instantly knew this was the time to update it.”

At the same time in London, Videotel’s CEO, Nigel Cleave, was thinking along similar lines. “We were delighted to have the opportunity to combine expertise and resources with MTS,” he said. “This partnership enables us to offer a new and updated approach to US Port State Control that will benefit ship owners, ship managers and seafarers the world over.”

The joint team worked together to produce a programme which covers all the very latest US Port State Control procedures. In particular, the US Department of Homeland Security’s Customs and Border Protection (CBP) immigration and agricultural inspections were a primary focus and MTS was given the opportunity to follow CBP officers on a real agricultural inspection and immigration procedure.“ CBP was a fantastic partner for us in producing this new programme,” adds Matt Gasparich. “They are committed to educating seafarers about new policies and procedures and were very open with the way crews could prepare for the examinations.”

CBP’s Seattle Area Port Director Mark Wilkerson added, “We were happy to participate in the making of this training video and consider this effort an opportunity to get CBP’s compliance information and requirements distributed to the maritime community.”

The programme covers the US Coast Guard inspection process, following a team of inspectors through a typical boarding with Coast Guard commentary on the best way to prepare ships and crews for inspection. The programme is available on Videotel’s VOD system and for purchase world-wide from MTS.

Shipping’s Impact on World Oceans Is Well Regulated Says ICS

When it comes to governing the oceans, shipping largely has its house in order – that is the view of the International Chamber of Shipping (ICS) whose Chairman, Spyros M Polemis, took part in a major debate about oceans governance, in Singapore (Feb 23rd and 24th).

Discussing ‘Who Should Rule The Waves’ at the World Ocean Summit, organised by The Economist magazine, Mr Polemis outlined how any suggestion of radically revising the United Nations Convention on the Law Of the Sea (UNCLOS) would not be welcomed by the international shipping industry.

Because of the delicate balance of rights and responsibilities that exists between flag states, port states and coastal states, the shipping industry is very reluctant to support a fundamental revision of UNCLOS.

Apart from enshrining the principle of global maritime rules, which are vital to the industry, UNCLOS also establishes the right of all nations to freedom of navigation on the high seas and the right of innocent passage in territorial waters. It also deals with delicate issues such as the rights of all ships to use international straits which are of great strategic importance.

Because UNCLOS addresses a number of other sensitive issues, not just affecting shipping, ICS believes it is very unlikely that governments would be willing to reopen what is a delicately balanced package.

The shipping industry has a 100 years’ experience of international governance of its activities, and questions the premise that the UN Law of the Sea is no longer fit for purpose.

Mr Polemis suggested that if there were concerns about other areas of oceans governance, lessons could be learned in other sectors from the shipping industry’s global regulator, the UN International Maritime Organization (IMO), whose successful MARPOL Convention is enforced and implemented by 150 Flag States covering 99% of the world fleet.

“Unlike many other activities involving the oceans, shipping is probably unique in having a specialist UN agency to regulate our activities – the International Maritime Organization. We have experience of many intergovernmental organisations that impact on our industry. I can honestly tell you that the IMO is a model of efficiency, made up of experts from virtually every government in the world, who develop and adopt very complex regulations directly relevant to the protection of the marine environment.”

ICS’s view is that there is no shortfall in governance so far as the international regulation of shipping is concerned. The shipping industry responsibly utilises the excellent facility that the sea provides for international transport – about 90% of world trade is carried by sea.

Mr Polemis informed the Summit that shipping’s environment performance is already comprehensively governed by IMO, which is a very efficient global regulator. The interaction between governments and the industry in relation to the work of IMO was just one of the pillars of the success story that is IMO. “Politicians should always consult with the industry when considering new regulation for shipping in order to avoid inefficient outcomes,” he said. He explained that shipping is a global industry requiring a global regulatory framework, not a patchwork of national rules which would bring about chaos, inefficiency and have a negative impact on the smooth flow of world trade.

Thomas Gunn Now Top Supplier of Navigation Services to Unicom Fleet

Thomas Gunn Navigation Services is delighted to announce that it has been awarded an important new contract by Unicom to supply an additional 43 vessels with its outfit management service. Thomas Gunn now supplies navigation solutions to 78 vessels, the bulk of the Unicom fleet.

“We value the strong business relationship we have built up with Unicom over a number of years,” says Thomas Gunn, founder and Managing Director of Thomas Gunn Navigation Services. ”We are very pleased that their positive experience of that relationship has enabled us to develop our partnership further, and are looking forward to working closely with them in the future.”

Thomas Gunn will supply the Unicom fleet with both Russian Hydrographic Office and UK Hydrographic Office charts and publications, in both digital and paper format, customised to the operating requirements and the vessel specific requirements of Unicom. Serving the mariner in the SOLAS regulated market for over 30 years Thomas Gunn is the world’s largest supplier of digital navigation solutions and paper charts.

Unicom is a member of the Sovcomflot Group, acting as an independent ship management company providing services such as full management, technical management, crew management, commercial management, full operation management including disbursement and freight and hire calculations, marine insurances & claims handling and project and newbuilding supervision.

Braemar to Market LNG Containment System Developed by General Dynamics NASSCO

Braemar Technical Services has signed a Memorandum of Understanding (MOU) with General Dynamics NASSCO to market a new, flat plate technology, LNG Containment System developed by General Dynamics.

The new containment system is a Type B tank designed to overcome the issues associated with partial filling and sloshing.

The system is built off hull and allows significant reductions in LNG carrier build time. The system is fully scalable and as such will be developed for all LNG markets including small scale units, LNG bunker vessels, LNG FPSOs, LNG FSRU and LNG FSU, barges and small scale land-based tanks.

According to Kevin Graney, General Dynamics NASSCO’s Vice President of Programs, “Our technology is designed to address several operational and shipbuilding constraints of existing LNG tank technologies while further enabling the use of LNG as a clean, sustainable energy source.”

Geoff Green of Braemar Technical Services stated, “It is clear that this new technology can play a major role in the development of LNG transportation and storage in the future and we are delighted to be working with General Dynamics NASSCO.”

Approval in Principle has been obtained from both Lloyds Register (LR) and the American Bureau of Shipping (ABS).

Braemar Market Insight: Changing Face of VLCC Spot Market

With so much discussion of the poor freight rates available to VLCC owners hiring their ships out for voyages from the Middle East to major consumers east and west, it is informative to see how much the spot market for VLCCs has changed in just a few years.

Since 2005, there has been a 25% reduction in reported AG/West spot VLCC voyages from 291 in 2005 to 216 in 2011. Just 11 AG/West fixtures were recorded in January 2012; if annualised the total would be 180, only 62% of the number recorded in just seven years earlier.

The US, the world’s largest oil consumer and traditionally the major customer for Middle Eastern oil, has diversified its supplies of energy with important effects for the VLCC market. The reasons for this diversification are complex and reflect not only market evolution, but changes to US economic, fiscal, environmental, and foreign policy.

According to the latest US Energy Information Agency (EIA), domestic crude oil production up reversed a long-term decline to grow from 5.18million barrels per day (m bpd) in 2005 to 5.47m bpd in 2010. Meanwhile, oil imports from Canada rose from 1.6m bpd in 2005 to 1.97m bpd in 2010.

More locally-produced oil will replace long-haul oil in a shrinking marketplace: the EIA 2012 Early Release Overview forecasts a 0.5% annual reduction in energy consumption per capita in the US between 2010 and 2035.

Meanwhile, high gasoline prices in the US have led to a reduction in domestic gasoline and diesel demand, with the US becoming a net petroleum products exporter for the first time in 2011 since the late 1940s.
Despite overseas demand for petroleum products refined in the US, a number of East Coast refineries have closed, if they rely on imported crude, as these cannot compete with US Gulf refiners with access to cheaper West Texas Intermediate crude oil.
China meanwhile has become the world’s second largest consumer of oil and, with an extensive refinery building programme underway, is in line to match US oil consumption within the current decade.
Consequently, the VLCC spot market has swung eastwards; in 2005, 20% of VLCC spot fixtures discharged in China; in January 2012, that had increased to 40%. Chinese oil refiners have swept into leading positions in the VLCC charter market. Discharges east of Suez now account for 85% of VLCC voyages out of the AG compared to 71% in 2005.
Mark Williams, Braemar Seascope research director, believes this swing to the East is now firmly entrenched. He says, “As Chinese refiners will probably add over 6m bpd of domestic refinery capacity in the next five years, their presence in the VLCC spot market is likely to increase further as China makes efforts to secure its energy supplies.”

ISF Launches New on Board Training Book For Engine Ratings

In order to take account of the 2010 amendments to the IMO STCW Convention, which came into force in January 2012, and which for the first time will make it mandatory for trainee engine ratings to provide evidence of structured on board training, ISF has updated its widely used On Board Training Record Book for Engine Ratings.

This is the second in a series of newly updated training record books, closely following the publication of a revised On Board Training Record Book for Deck Ratings.

The revised ISF Book contains structured on board training tasks formulated around the competence standards stipulated by STCW 2010, including those adopted by IMO for the new grade of ‘Able Seafarer Engine’. Most Flag States are in due course expected to require many existing engine ratings to be certificated as Able Seafarer Engine as part of their minimum safe manning requirements.

As the principal international employers’ organisation for ship operators, representing national shipowners’ associations from 30 countries and about 80% of the world merchant fleet, ISF wishes to ensure that rating trainees make the best use of their seagoing service.

ISF Secretary General, Peter Hinchliffe explained:
“The competence of marine engineers, whether ratings or officers, is critical to safety and environmental protection. The updated ISF Book enables trainees and their companies to monitor, record and evaluate their on board training in a structured manner in accordance with the new STCW Convention requirements.”

The On Board Training Record Book for Engine Ratings can be purchased from maritime booksellers, or direct from Marisec Publications for UK £25 (including airmail postage) or for £18 when five or more copies are ordered. To place an order, please follow this link:
http://www.ics-shipping.org/EngineRatingsOrderForm.pdf

InterManager President Made Fellow Of Nautical Institute

Alastair Evitt, current President of international ship management association InterManager, has been made a Fellow of The Nautical Institute.

Mr Evitt, Managing Director of Meridian Marine Management, is set to be formally presented with his Certificate of Fellowship at this Thursday’s Annual General Meeting of the North West England & North Wales Branch of The Nautical Institute in Liverpool (Feb 16).

Rear Admiral JS Lang FNI, chairman of the Council’s Fellowship Committee, said: “Fellowship of The Nautical Institute is only awarded to those who have made a significant contribution to nautical science, the nautical profession and/or the objectives of the Institute.”

Mr Evitt said: “It is a great honour to be made a Fellow of The Nautical Institute and I will use my best efforts to further the work of the institute and actively contribute to its work.”

ICS Board Meets In London

The Board of Directors of the International Chamber of Shipping (ICS), whose member national shipowners’ associations represent all sectors and trades and more than 80% of the world merchant fleet, met in London on 6 February.

Piracy
ICS members reviewed the continuing threat to shipping from Somali pirates in the Indian Ocean. Noting that the capability of Somali pirates is actually higher than it has ever been, ICS believes that effective compliance with Best Management Practices by shipping, and sustained military intervention with a more aggressive stance, has reduced the pirates’ rate of success. However, the current situation remains totally unacceptable, with about 200 seafarers still being held hostage in the most appalling conditions, with thousands more still having to transit the danger area in constant fear of their lives.

ICS national associations agreed to work to ensure that the problem of piracy retains sufficient political and public attention so that the crisis might be properly and decisively addressed during the year ahead.

ICS Chairman, Spyros M Polemis explained:
“Recent press reports might give the impression that the level of piracy off Somalia is decreasing. However, most ship operators will be aware that this is not an accurate representation of the current situation. The ICS Board has therefore identified three specific immediate objectives:

We need to persuade governments to task the military to take the attack direct to the pirates, while at the same time continuing to defend merchant ships in the best way possible. Second, every apprehended pirate should be arrested, taken to a court of law and, if found guilty, imprisoned. Thirdly, governments must break the financial chain through legal action against criminal financiers investing in piracy wherever in the world they are identified.”

ICS welcomed the international conference on Somalia that will be hosted by the United Kingdom on 23 February, and agreed that its member national shipowners’ associations will lobby their governments hard, in advance of the international conference, with respect to the three key objectives identified by ICS.

Reducing CO2 Emissions
The ICS Board reviewed the industry’s position with respect to progress being made at IMO on further measures to reduce CO2 emissions from international shipping, including refinements to the Energy Efficiency Design Index (EEDI) – which was adopted as part of the ground breaking international agreement reached at IMO in July 2011 and which will apply to new ships from 2013 – and discussions at IMO about possible Market Based Measures (MBMs).

ICS also reviewed the operational and technical measures now being taken by existing ships, in support of the industry’s target of improving efficiency per tonne/km by 20% by 2020. With respect to the EEDI, ICS confirmed its complete opposition to the application of the EEDI to existing ships.

“This is not what the EEDI was developed for, and the goals set for the design of new ships, and the complex formulae developed for them, are completely inappropriate for the existing fleet.” said Mr Polemis “ICS will be making the industry’s considered view on this clear at the next meeting of the IMO MEPC.”

ICS also confirmed its strong opposition to a proposal from the Bahamas to IMO whereby governments would specify limits on the CO2 emissions of individual ships (as determined by fuel consumption) and which would subsequently be reduced over time.

“If a ship’s CO2 allowance was exceeded during the time period specified, it would have to go off-hire and a second ship chartered as replacement. The problem is compounded by the reality that the fuel consumption of two identical ships can vary dramatically according to trading patterns and other variables such as weather. ICS members confirmed that such an approach was very worrying and should be firmly opposed.” said Mr Polemis.

The Bahamas’ proposal has been made with the apparent intention of being an alternative to other Market Based Measures that have been proposed at IMO. ICS is concerned that some might see this as being a superficially attractive means of stopping the adoption of an MBM.

Mr Polemis remarked “As well as being highly damaging to large parts of the industry, the Bahamas’ proposal would alter the level playing field and distort competition.”

The ICS Board also discussed the outcome of the UN Climate Change Conference in Durban, which has agreed to establish a Green Climate Fund for developing countries, seeking $100 billion a year by 2020, and proposals by the World Bank that shipping might be expected to contribute a quarter of this money.

Mr Polemis remarked “The ICS Board agreed that many governments seemed more interested in how much money can be raised from shipping, rather than the progress we are already making in reducing our emissions through technical and operational measures. We have said it before, and we will say it again, shipping is not a cash cow and should never be seen as one. Any such notion will severely damage shipping’s competitiveness and thus adversely affect the consumer greatly.”

Mr Polemis added “It is internationally accepted that IMO is the appropriate forum for discussion about further CO2 reduction measures by shipping, and it is counter-productive and will crucially affect the level playing field if the EU was to adopt a regional Emissions Trading Scheme for shipping. The focus must be on collective discussions about a global approach.”

Costa Concordia
The ICS Board discussed the Costa Concordia tragedy and agreed that the disaster would certainly influence the regulatory agenda of IMO, and that the industry would contribute constructively to the discussions. ICS would welcome the earliest possible publication of the Italian accident investigations.
ICS acknowledges that the safety performance of the industry will be under review, but it is still far too early to know what the detailed outcome of the accident investigation will be and it is therefore not appropriate for ICS to provide any definitive comment on the incident. ICS reiterates that safety of life at sea is always the industry’s highest priority, and ICS will contribute fully and constructively in the discussions at IMO, or in other regulatory bodies, that take place in response to this major casualty.

Cargo liquefaction
The ICS Board expressed serious concern about the recent loss of several ships carrying nickel ore/iron ore fines loaded in India, the Philippines and Indonesia, apparently due to cargo liquefaction causing cargo to shift dramatically. ICS members were especially disturbed by the recent tragic loss of 22 crew on the Vinalines Queens after loading a nickel ore cargo in Indonesia.

ICS acknowledges that the issues are complex, but the root of the problem would seem to be the refusal of some shippers to allow the appointment of independent surveyors to conduct cargo testing in accordance with IMO requirements – plus the commercial pressure placed on masters to accept potentially unsafe cargoes at what are often remote locations.

The ICS Board agreed that the prevention of similar incidents was of the utmost priority and that in co-operation with IMO, insurers, and the governments of those nations where problems seem to exist, ICS would endeavour to help find a solution that would assist shipowners and shipmasters to resist any pressure to accept unsafe cargoes.
—ends—

Notes To Editors:
• The International Chamber of Shipping (ICS) is the principal international trade association for shipowners, with member national associations from 36 countries representing all sectors and trades and over 80% of the world merchant fleet.

For Further Information, please contact:
Elaborate Communications, Debra Munford (UK) Tel +44 (0) 1296 682124
Website ics-shipping.org

InterManager Starts Year With Expansion

InterManager, the international trade association for the ship management industry, has started 2012 with significant expansion.

In the first month of this year InterManager has welcomed two Full Members – ship management companies Histria and Green Wave – and two Associate Members – international law firm Hill Dickinson and crew communications provider SMART Link.

And building on this momentum, InterManager has appointed Captain Paddy McKnight to the role of its International Maritime Organisation Permanent representative. InterManager was previously represented at the IMO by Svein Sorlie of Wilh. Wilhelmsen Holding ASA, who has now retired from shipping.

Captain William (Paddy) McKnight spent 37 years in the Royal Navy, during which time he Commanded three warships – HMS Shetland (an offshore fishery protection vessel) and frigates HMS Leander and HMS Brave – and was second-in-command of The Royal Yacht Britannia. He was later Captain of the Royal Navy Presentation Team followed by a diplomatic posting as Naval Attaché to Rome, Italy.

On leaving the Royal Navy he spent 15 years as the UK representative at The Japanese Shipowners’ Association which entailed interaction with all the leading shipping trade organisations as well as the IMO. In particular, he was a member of the shipowners’ delegation throughout the genesis and development of the Maritime Labour Convention at the ILO in Geneva. Capt. McKnight was promoted Lieutenant of The Victorian Order in 1985 and subsequently appointed as a Gentleman Usher to HM The Queen in 1999.

InterManager Secretary General Captain Kuba Szymanski said: “We are delighted to welcome Paddy to InterManager’s team and look forward to working with him. He is an industry veteran with the characteristics we believe this position demands and his presence at the IMO will enable us to ensure our organisation is fully appraised of key industry matters and that our members views are suitably represented.”
—ends—

Notes to Editors:

• Histria Shipmanagement manages a fleet comprising nine modern shallow draft, high cbm, fuel efficient 41,000 dwt oil-chemical tankers, including two newbuildings under construction at Constanta Shipyard. Future plans include the building of two 50,000 dwt shallow draft, high cubic, fuel efficient eco-design oil/chemical tankers scheduled for delivery in 2013.
• Formed in 1992, Histria Shipmanagement is part of the Histria Group of Companies and encompasses a network of corporate vehicles engaged in ship management, chartering, operation, crewing, repairs and upgrading, technical maintenance and safety at sea for a growing fleet of tankers, bulk carriers and general cargo vessels ranging from 3,000 to 164,000 dwt and totalling an aggregate of more than 650,000 tdw.
• The Romanian-based company was amongst the first European shipping companies awarded the International Safety Management Certificate IMO A 741(18) by Germanischer Lloyd in October 1997. The company has recently updated and restructured its Integrated Management System to give added value to its capabilities to manage a modern fleet.

• Green Wave Shipping Pte Ltd is a Singapore-registered company managing a small fleet of modern stainless steel chemical tankers. The company is a subsidiary of Koyo Kaiun Co. Ltd.

• Hill Dickinson’s international marine, trade and energy practice encompasses more than 100 dedicated marine legal experts based in London, Piraeus, Singapore, Liverpool and Manchester. The practice comprises four teams – yacht, shipping, commodities, and cargo, freight and logistics. Each of the marine teams works closely with an international network of maritime lawyers, marine surveyors, investigators and loss adjusters to provide the complete marine legal service 24/7.
• Hill Dickinson’s enrolment enables InterManager to reacquaint themselves with former member Ian Maclean who has now moved to Hill Dickinson having previously been with Ince & Co.

• Philippines-based SMART Link provides satellite communication for the maritime industry with an estimated 120,000 active subscribers. Backed by telecommunication company SMART Communications Inc, SMART Link serves seafarers in the Asia-Pacific region, Indian Ocean, Middle East and parts of Europe and America and is installed on some 7,500 vessels.

Videotel Helps Reduce the Dangers of Visiting a Ship in Port

Whilst many are aware of the hazards faced on board a vessel at sea, often little attention is paid to the difficulties and dangers encountered during the seemingly simple act of visiting a ship in port. Yet the terminals and ports a vessel serves are as potentially dangerous an industrial environment as most people are ever likely to encounter, with changing circumstances leading to changing risks.

Videotel Marine International has launched a new training programme, Ship Call – Visiting a Ship in Port, designed to provide all those who visit ships the training needed to reduce the risks involved in any ship call.

“Seafarers are highly trained, but in the past even they have come to serious harm boarding vessels,” says Nigel Cleave, CEO of Videotel. “The situation is even more hazardous for visitors to ships who often lack training and experience. Individuals are expected to board vessels both day and night – often under time pressure – and in all types of weather. Tackling a gangway; alighting from a launch; using a ladder; all have their own inherent risks.

Ship Call demonstrates graphically how visitors to ships can avoid the risks involved with any visit to a ship in port. Divided into three sections, the first shows how to prepare for the trip and the second looks at the risks involved in boarding the vessel. If boarding by launch, this would include monitoring the weather conditions, inspecting the launch for any hazards and checking the sea conditions before attempting to board.
The final part addresses visitor safety while actually on board, ensuring that key safety procedures are adhered to and all appropriate safety equipment is used.

Addressing a range of maritime safety regulations, the programme is especially valuable for those joining a ship for the first time, but is targeted at all maritime professionals needing to board or leave a ship in port.

Ship Call – Visiting a Ship in Port is available in VHS/DVD with supporting booklet, and via interactive CD-ROM.

Is Another Demolition Spike Due? Asks Braemar Seascope

As the Baltic
Dry Index plumbs all-time depths, those with long memories are recalling the
dark days of the 1980s for the shipping markets.  However, steel traders can look forward to a
bumper year of supply of vessels for recycling this year, if previous
experience offers a guide for the 2012 outlook. Bets are now being taken about
how many vessels will be forced by the weak freight markets into the arms of
recyclers.

 

Globally, ship
scrapping capacity has very big limits being a simple business of driving ships
onto beaches and cutting them up with oxyacetylene torches. Theoretically,
great numbers of ships could be sold for scrap and held as inventory by the
scrap dealers, to be pushed up the beach as and when required. Scrap prices for
ships of around USD $500 per light displacement tonne (LDT) remain, suggesting
that demand for the steel content in ships remains strong.

 

Meanwhile,
ship recycling capacity could grow further in coming years. The China State
Shipbuilding Corporation President said recently that half of China’s shipyards
could go bust in the next two to three years. Many of these yards could switch
to recycling as, theoretically, could European shipyards, though the economics
of recycling in Europe are currently not encouraging.

 

Braemar
Seascope estimates that,  in 2011, 24.2m
dwt of bulk carriers were sold for scrap, surpassing the 12.0m dwt scrapped in
2009 during the credit crunch, and the 11.5m dwt scrapped in 1998 after the
Asian financial crisis, as well as the 15.0m dwt scrapped in 1986, the year the
BIFFEX bottomed out at 554 points on 31 July. 
2011 was not a record-breaking year for tanker recycling despite the
poor freight markets.  For four years
from 1982 to 1985 over 20m dwt of tankers were recycled while 14m dwt was sold
for demolition in 2010. Last year saw 8.4m dwt of tankers recycled, with the
figure for January 2012 maintaining the trend.

 

Scrapping of
all types reached 41m dwt in 2011, making it the third biggest year for
demolition ever. The second biggest 1986 when 43m dwt was scrapped, and the
biggest ever was 1985 with 44m dwt sent to the beaches. Mark Williams, Braemar
Seascope research director in London, said: “If macro-economic conditions in
2012 continue to underwhelm and if scrap prices stay at their recent high
levels, this year could easily surpass 1985 as a peak year for demolition.”