28th September 2010 http://www.scotlink.org/files/policy/ConsultationResponses/LINKmtfConsultShip2ShipReg10.pdf
LINK MTF strongly believes the ship-to-ship transfer of oil must be regulated, and we reiterate our support for the measures set out in the Merchant Shipping (Ship to Ship Transfers) Regulations 2010.
The 2005 proposals for ship-to-ship (STS) transfers of oil in the Firth of Forth highlighted significant deficiencies in the regulatory regime controlling the handling of oil in UK waters. LINK MTF members are supportive of the Merchant Shipping (Ship-to-Ship Transfers) Regulations 2010, which were designed to rectify this situation. Such measures are essential to protect our marine environment and ensure the UK and Scottish Governments meet their obligations under international, European and domestic environmental law.