1.

TERMS OF REFERENCE:

1) To identify the factors leading to congestion of trailers both inside and outside the container terminal. 2) To assess the space requirements for customs appraisement of containerized import and export cargo inside the terminal. 3) To suggest most vantage locations inside the terminal for customs appraisement 4) To suggest the ways and means for upgrading the existing facilities 5) To suggest other administrative measures for reducing truck detention inside the terminal in course of Customs examination of load containers.

2.

METHODOLOGY: a) Consultation with the representatives of the port users. b) Gathering data relating to traffic movements at the entry and exit gates of the terminal. c) Gathering data relating to appraisement of various categories of cargo inside the terminal and at the CFSs outside. d) Site inspection. e) Obtaining feedback from the port users through formatted questionnaire.

3. 3(A)

PRESENT SCENARIO: Trailer movement pattern outside the terminal: At present in Kolkata Docks (KDS), there are 4 numbers dedicated container berths,

namely 4NSD, 5NSD, 7NSD and 8NSD which cater to the container ships visiting KDS. In the event of bunched arrival of ships, or any of the mentioned berths not available, container ships are also worked at the berths at 2NSD and 3NSD and rarely at 1NSD. Both load and empty containers are shipped or landed at the mentioned berths, while occasionally berths at 13NSD and 14NSD are also utilized for shipment/landing of only empty containers. 13-14 NSD area, being an isolated place from the main terminal and also being casually utilized by the container ships has been excluded from the purview of the present study. In the main Terminal and the adjoining 1-3 NSD area the exim containers move through 7 IN and OUT gates, as indicated below: 3GRJ gate, opening on BraceBridge Road For moving in empty containers. Also used for moving in break bulk cargo, for 1-3NSD area. 3NSD gate, opening on N.M Road For moving out empty trailers and also break bulk cargo. 6NSD gate, opening on N.M.Road For moving in empty trailers for clearance of import boxes. 4NSD gate, opening on C.G.R Road For moving in export load reefer or special boxes in the Ist shift of work and thereafter for moving load import boxes out. 7NSD gate, opening on C.G.R Road For moving import load boxes out, and also break bulk cargo of 7NSD CFS. 8NSD gate, opening on C.G.R Road For moving out import load boxes till 13.00hrs. and entering export load boxes thereafter. 8A NSD Gate, opening on C.G.R Road For moving in empty trailers for removal of import load boxes to CFS; also serves as Rail gate for movement (in and out) of rakes of railway wagons. It may be seen from the above (plate no.1) that out of the 7gates mentioned 4 gates which are spatially located only at about 200/300 yards interval are all opening on the same C.G.R Road which is a public thoroughfare and main arterial road of the locality as a whole and for this reason traffic density remains very high on this stretch of the road, for most part of the day.
2

N.M road and Brace Bridge road are actually branch road of C.G.R Road and dock bound traffic plying on these two roads at present also pass through C.G.R Road for want of diversion road which was earlier available when the Swing bridge of KPDock was available for vehicular traffic. Due to the above disposition of the 7 entry/exit gates of NSD, the entire exim traffic of 1NSD to 8NSD area inside the docks uses the circumscribing C.G.R Road and its branch N.M Road and B.B Road out side, covering a stretch of only about 2.5 K.M of road length. The average width of the carriage way for this stretch of the road is about 50 only. (see plate-1). Thus entire container traffic passing through NSDock roll on/off a stretch of only 2.5 k.m x 50 road space outside-- almost entire portion of which, barring B.B Road is again a part of a very busy public thoroughfare. The nearest branching ways through which these C.G.R Road traffic get diverted or congregated are Sonai Road, at a distance of about 100 M, Hide Road, at a distance of about 500M and at Coal Dock Road at a distance of about 700M from 4NSD gate on the east. These branch roads are however quite narrow. Hide road, a very busy public thoroughfare again, links three CFSs ( e,g Balmer Lawrie &Co and Century Ply Sonai and JJP) with the Docks. Similarly Coal Dock Road connects CFSs of C.W.C and CONCOR. All these five mentioned CFSs are proximally located within a radius of 3K.M from NSD. Although the container terminal works round the clock, it is seen that on any given working day trailers loaded with containers starts rolling out of the exit gates not before 11.30 hrs. Similarly, entry of trailers, empty or with export load boxes, starts entering the terminal not before 10.30 hrs. Thus about 18 to 19 hrs a day entry/exit gates actually serve the trailers which are visiting NSDock.

3(B)

Trailer movement pattern inside the terminal (plate no. 2):

A. Export: Export load container that visit the terminal can be divided into two broad groups: a) Which require Customs appraisement inside the docks, after entry. b) Which require only seal checking by the Customs. For the containers falling under category a) it is required that the subject containers, immediately after entry, are taken to an appraisement zone for physical inspection of the cargo. Containers falling under category b), however, do not require any specified area for its seal

inspection, which can be done while the container is lying on the trailer. After completion of customs formalities the export load containers move to their respective export berth for grounding. At present customs appraisement of load export containers are done at two nominated areas inside the terminal. Those are at G-berth-NSD and at the facility situated in the erstwhile truck terminal located at a distance of about 150 yards from the S-E corner of the CFS building. Mentioned customs appraisement areas being located at a distance of about 600M and 200M respectively from the entry gate no 8NSD, trailers loaded with export boxes can visit the places quite easily following unidirectional movement without interfering other traffic flow in the area significantly. After completion of appraisement, these trailers can also move to their respective export stacking yards, which are basically continuation space of the berths itself, following unidirectional movement inside the terminal. But en route encounters cross flow of import traffic at various places. For the export containers requiring only seal checking by the customs official, till now for want of facility at the entry gates, customs officials undertake the checking at places inside the terminal as convenient for them. The space at the adjoining area of the G-berth is also utilized quite occasionally. After completion of seal checking formalities the trailers move to the respective export berths for depositing the boxes. After depositing the export boxes at their respective export stacking yards, the empty trailers goes out of the terminal through 3NSD gate. While approaching 3NSD gate these empty trailers however tend to merge or overlap with the traffic flow direction for out bound traffic generated at 1 to3NSD area and also with that of the trailers bringing in empty containers through 3GRJ gate either for dumping at block no 10 at the erstwhile Basra yard , east of 4/5 NSD,or for direct shipment on vessel at 4NSD to 8NSD.

B. IMPORT: Besides the yards attached to the berths, space available at block no 15 at erstwhile Basra line is utilized for stacking of general import boxes, particularly of vessels which work at 2,3,4 and 5NSD berths. While moving the boxes the trailers encounters cross flow with the export boxes moving towards the berth attached export yards, particularly at 2,3 and 4NSD area, as mentioned earlier. Import containers are subsequently delivered from the yard stacks to the consignee or removed to the off dock CFSs.

Containers which are allowed delivery to the consignee (other than Nepal/Bhutan) are required to be appraised inside the terminal by the customs official. For effecting such appraisal, the boxes are required to be taken to the appraisement sites at the G-berth area or at the yard located at S-E corner of the CFS building, mentioned earlier. Such containers, particularly those which are kept at Basra yard, while moving towards the mentioned appraisement zones faces cross flow on the stretch of road lying between Basra yard and 7NSD CFS. After appraisement all load import boxes move toward 7NSD gate and 4NSD gate for final exit. While approaching the 4NSD gate they get merged with export boxes which are destined to 2NSD to 5 NSD area, over a certain distance. Containers which are meant for CFS removal or Nepal/ Bhutan bound are not appraised, but are sealed by customs, prior to their exit through 7NSD or 4NSD gate. Such sealing of containers is normally done at places convenient to the officials and there is no earmarked area inside the terminal available for that. C. RAIL BORNE EXIM: At present entire rail borne EXIM container traffic, and occasional break bulk traffic is handled at block no- 1 of the 7-8NSD CPY. As a result, rail borne containers which are originating at or destined to 2,3,4,5NSD berths face cross flow of traffic at various places, depending upon its originating point or stacking location inside the docks.

D.

EXIM EMPTY CONTAINERS: There are a number of plots of land (dump) most of which are located within a distance of

11/2 K.M from NSD, which are used for temporary storage of exim empty containers. Movement of empty containers between these plots and the docks take place following the same route, as followed by others, outside the docks. Inside the terminal those are not required to be taken to any customs appraisement area and are stacked at block no-10, at old Basra yard from where all the vessels working at 2NSD TO 8NSD berths are fed with empty containers, or are taken delivery. Since empty containers enter through 3GRJ gate, after entering the docks, enroute block -10, as mentioned, they enter cross flow of traffic behind 4NSD. At the time of feeding the ships from this location they faces cross flow of traffic at various places depending upon the location of the destination berth.

E.

REEFER EXIM CONTAINERS: Like the rail borne containers, Exim load reefer containers are entirely taken at Block No

6, opposite 7NSD CFS. As a result, similar to rail borne exim these boxes which are originating at or destined to 2,3,4,5NSD berths face cross flow of traffic at various places, depending upon its originating point or stacking location inside the docks.

4. CONGESTION- REASONS:

4(A)

Physical factors:From the above deliberation the following physical factors could be identified which

causes congestion in the traffic flow inside the terminal and also outside:a) Cross flow of traffic inside the terminal, primarily due to peculiar lay out of the berths, container stacking yards and entry/exit gates b) location of rail serving block, c) location of reefer yard , d) narrow roads inside the terminal e) narrowness of the dock peripheral road (C.G.R Road,N.M Road, B.B.Road) f) spatial closeness of the entry/exit gates g) limited no of diversion road and their narrowness h) high traffic density in the peripheral as well as in diversion roads.

4(B)

Procedural factors:Besides the above physical factors, there are procedural issues which tend to cause

detention to the exim traffic inside the terminal. Those are: I) II) Customs appraisement Submission of shipping documents by the users.

From a randomly selected sample analysis, it is seen that the trailer detention inside the terminal for clearance of import container may vary between 25min and 2days and 6 hours, with average figure of around 9hrs. In case of exports such stay period of trailer ranges between 12 mins and 4 days and 15 minutes, with an average figure of 10hrs. The service time at the gates was found to be varying between 3 minutes and 15 minutes.
6

The above detention figures indicate the following inadequacies in the system: a) Detention due to handling equipment shortage b) Detention due to customs appraisement and port documentation. c) Detention due to trailer driver not being prompt to place and/or move out the trailer. d) Detention at the exit gate due to congestion. e) Due to congestion inside the terminal at the service point.

Although for want of data, average detention item wise in respect of the above factors could not be assessed it is generally believed that detention in customs appraisement is one of the major causes contributing in the matter. Detention in customs appraisement process occurs in many cases primarily due to Inadequacy in the infrastructure, untimely/delayed submission of documents by exporters/ CHAs, delays in readying cargo for appraisement, delays during examination of cargoes requiring destuffing as per examination norms. As stated earlier for container traffic in NSD there are two locations made available for customs appraisement, one at G-berth and the other at a distance of about 150 yards from the S-E corner of the 7NSD CFS. At the G-berth there is a raised platform of about 5 feet high with capacity of positioning 20 trucks at a time is available, while at the latter place a 4 feet high platform of capacity of 15 trucks is available. Width of both the platforms being narrow, it does not allow destuffung of the boxes in course of appraisement. Moreover at G-berth no covered shade is provided, while that of the other is found to be of appropriate dimension to protect the cargo from rain. Lighting arrangement at both the places are either nonexistent or insufficient.

5.

Scenario- Immediate future:-

From randomly selected sample analysis the following assumptions can be made: i) Commensurate with the present trend in KoDS, the container throughput of the berths 2-8NSD has been showing + ve growth during the current year. It is likely that during the current fiscal such throughput level may reach the figure of about 4,25,000 teus or 3,50,000 boxes.

ii)

On a month to month basis the throughput level for the mentioned berths may reach the peak value of 40,000 teus= 32,000 boxes in a month, against the present monthly average of 37,290 Teus = 29150boxes per month.

iii)

The peak value of gate entry & exit volume at the mentioned gates in a day, after taking into consideration the rail borne volumes of exim containers of 3000 teus per month, may reach the level of 1500 teus, against the present average figure of 972teus and peak figure of 1350 teus.

iv)

The rail borne container handling in a month may reach the level of 2800 boxes against the present average of 2457 boxes.

The above position gives one a fair idea about the nature and extent of the system load pressure the yards, gates, rail and finally the outside road network will cater to very soon. Amongst the 7 gates mentioned 4 are utilized for entry of trailers with or without containers and remaining 3 are utilized for exit of trailers with or without containers. Since volume wise the import and export containers passing through KoDS is almost equal ( 15.5:15.1), above allocation of gates roughly matches the pattern of exim traffic visiting NSDock. It may, however, be noted that gate no 3GRJ, 3NSD,4NSD and 7NSD are also utilized by the break bulk exim traffic. 90% by volume of such traffic, being generated at 1NSD-3NSD area, uses 3GRJ and 3NSD gates. These being an additional requirement these two gates remain comparatively more congested. The volume of traffic ultimately plies through the outside peripheral C.G.R road, mentioned earlier. A fair percentage of these traffic being CFS bound avail diversion route at Sonai road crossing, Hide Road crossing and Coal Dock Road crossing. According to the available data during the period April-November, 2012 CFSs of Balmer Lawrie &Co and Century Ply (JJP), both of which are operating on the same connecting road (Hide Road) collectively evacuated 46,461teus, while C.W.C, operating on Coal dock road, 29,475 teus and Century Ply(Sonai) 22,075 teus import load boxes ex KoDS. Export feeding from those CFSs is yet to acquire significant volume. However, there are a number of pvt warehouses on all three mentioned roads from where significant volume of export load boxes arrives in NSD. Figures in respect of this volume is however not available. This however gives a fair idea about the container traffic pressure that has already developed on these diversion roads. Since all these CFSs and warehouses, and also the empty container dumps are located within a radius of 4 to 5 K.M from NSD, the entire area, for good part of the day and night hours
8

remain congested with container traffic and other vehicular traffic of the local road network, surrounding NSD. Random sample data analysis revealed that in a day, during the first shift of work gate receiving figure for containers is higher than that of gate delivery figures by about 80%, total gate work volume is highest in the second shift, followed by the ist and then 3rd shifts (receiving and delivery together).On holidays and Sundays, although the terminal works fully, the exim container movement through the gates reduces by 30 to 50%, compared to the normal working days. Customs Appraisement of EXIM Containers Present position: 1) As per the data furnished in Annexure 1.of export containers shipped during the period of May 2012 to October 2012 through NSD, it is observed that on an average basis around 9500 containers were permitted to export in a month. Out of 9500 containers shipped on an average per month, around 5000 containers per month were Central Excise sealed requiring only seal checks and 4200-4500 per month (except October2012) were under appraisement category wherein examination is conducted. 2) In addition to above at an average 35-40 number of containers per day for Imports appraisement and seal check for Non-facilitated and facilitated Bills of entry respectively filed by Customs ACP clients and Ports volume importers are presented for clearance. 3) As already mentioned in point 4 (B) para no.6, the designated appraisement areas inside NSD are only G-berth area (capacity of 25-30 boxes) and S-E corner behind CFS building near gate no.8 (capacity of 15 boxes). Besides these two areas, due to acute space constraint roadside area leading to berth no 7 is also being used for exports examination. Thus the locations nominated for customs examination are grossly inadequate and insufficient and despite increase in exim traffic, present capacity does not support examination of more than 60-70 containers at a time whereas the requirement is to examine around 150-175 exim containers on an average per day. 4) Due to the non availability of raised platforms and space scarcity as discussed above, goods already stuffed inside the containers mounted atop trailers/ lorries are presented for examination which is neither recommended nor appropriate method of examination where content verification is always difficult. Goods are being destuffed by dock labourers from the mounted containers and dumped on grounds and re-stuffed after examination which is a major cause of increased dwell time and traffic congestion.
9

6.

Moreover such a method of destuffing results in packages being soiled and damaged in particular if the consignment is one of goods like tea that are very sensitive to dust and moisture. 5) The destuffing and thus resultant examination of Bulk and non-bulk commodities in particular becomes challenging in NSD because as per CBEC circular 06/2002 dated23/01/2002 for examination of export consignments prescribes for different examination norms according to the benefits/incentives claimed by the exporter and destination of goods. Such destuffing of packages ranges between 2% to 50% of the packages depending upon the scheme and destination. 6) It is physically not even possible to bring out the packages if they are in form of huge and bulky jumbo bags of commodities like rice, rice bran, tea, wheat etc or pallets of mechanical cargo which often weigh equal to or more than one ton 7) Moreover no stuffing of cargo facility as per procedures is available inside NSD and is also not very popular amongst the exporters

7.

Recommendations for systemic improvements:In consideration of the above scenario, and particularly in view of projected container

traffic growth of KoDS for the coming years ( 5,00,000 teus and more) the committee makes the following suggestions for overall systemic improvement, in and outside the terminal. A. Outside the terminal: i) The approaching lane for the gates, particularly at 3GRJ and 7NSD, is so narrow

that one trailer capsizing or remaining out of order while on the queue may cause considerable bottleneck. Similar situation may also occur if trailer which is not ready in all respect precedes the others on the queue at the entry gate. Concerned authority may be requested to examine the scope for widening these feeder lanes. In respect of 3GRJ gate the plot of land available near the Lybian ware house may be developed and used for small truck terminal for dock bound container trailers only. ii) The scope for enlarging the existing fee-parking zone , behind ITC factory may

be examined and cooperation from the Police authority may be sought for ensuring smooth entry and exit of vehicles there. This will reduce the number of idling trucks which tend to congest the arterial C.G.R Road and the mentioned diversion roads.
10

iii)

The scope for early re-commissioning of the Bascule bridge for use of the

vehicular traffic, including container-trailers may be examined with due priority. iv) The road repairing and widening works on the C.G.R and diversion roads should

be completed v) The empty container depots and dumps should be kept operational in sync with

the docks, which most of them are not doing on Sundays and holidays at present.

B. Inside the terminal: i) The document and security checking by the C.I.S.F at the gates should be speeded

up as far as practicable. As mentioned earlier the security checking and gate service being fairly high (between 3mins and 15 minutes) efforts should be made to improve upon the position and for that port users may be given the scope for generating their respective EGP at their own offices. Present CFS operators who are already given this facility (e.g Balmer Lawrie, C.W.C) are not using the facility in a regular manner or at all. C.I.S.F authority may also examine the scope for introducing one step checking procedure in place of their present2/3 steps procedure, which is adding to the detention to the trailers at the gate.

ii)

For exit of trailers carrying import boxes in more number during the day shifts,

particularly those which are moving to CFSs, the CFs operators should complete all documentation ( Form-1, port charge payment, EGP) well in advance and co ordinate the operations with their respective transporters and ensure early attendance of their representative at the site of operations.

iii)

Delivery/Removal of import load containers in more numbers during the day shifts

of work should be encouraged.

iv)

Service time for the trailers inside the terminal should be reduced further, by

expediting the documentation and loading/unloading operation. At present there are 4 number RTGs which are deployed at 7-8 NSD CPY, 6 RSTs (of which 5 are available, one being in maintenance),engaged by KoPT for handling of containers in the yard to carry out ship feeding, container receiving/delivery, wagon loading/unloading operation. Besides, there are 2RSTs engaged by M/s ABG at 4NSD
11

yards. Out of 4RTGs, one is lying out of commission for quite a long period and the productivity in operations of the remaining three are generally not satisfactory, primarily due to their old age. It is quite often particularly when there are 5 container ships working simultaneously, and there is a wagon rake loading/unloading programme, the available equipment fall short of the number of points of operations. Due to the shortage in equipment in such situations, trailers/wagons get detained to increase, dwell time of trailers inside the terminal. Scope for early repairing of the long idling RTG, as mentioned, and also increasing the number of RSTs suitably be explored, as it is held that due to unsteadiness in navigable draft availability in the river, ships would continue to arrive in bunch, requiring simultaneous ship operations at 4/5 berths. KoPT authority is contemplating installation of MH crane at 5 NSD very soon. This being crane of higher productivity, it will commensurately increase the requirement of RST and trailers to back up in the yard.

v)

At present on an average less than 800 TEUs of import load contaiers out of around

13500 TEUs, forming only 6% by volume move to CFS by rail from the terminal in a month. Movement of boxes between the terminal and CFS in greater volume, both ways, should be encouraged. For that Balmer Lawrie & co may explore the possibility of increasing the number of wagons from 15 at present. Other CFS operators except CONCOR should also examine the scope for establishing rail connectivity with the terminal. Port authorities should also ensure better engine availability for serving the traffic once the volume picks up. vi) By providing vantage locations for Customs examination and alternatives thereof.

7. B. (1) Vantage locations for Customs examination- A study

(i)

Alternative location inside NSD:-

The committee inspected all the vantage points inside NSD to propose an alternative location for examination and identified shed no.3 (with huge two platforms running parallel) near 3NSD gate. A portion of these platforms and the shed at its western side can be utilized for the Customs examination in a limited way in view of the fact that the area in question remains fairly congested due to convergence of outbound traffic, passing through 3NSD gate as also vessel
12

bound containers. At the most 7 to 10 import containers can be appraised at a time at this place provided the job can be completed expeditiously, as longer stay of such trailers at this place would cause serious bottlenecking. To start with, containers discharged by the vessel at 2-3 and 4NSD berths can be taken for appraisement at this place. Similarly, southern end of western platform of 7 NSD CFS can also be used for examining export boxes in batches of 7-10 at a time. In any case allocation of lager space for Customs examination inside the terminal is found to be very difficult due to operational reasons.

(ii)

Alternative location outside NSD:-

The committee further examined the issue of movement of export loaded containers through CFSs/ ICDs as in case of imports. CFSs /ICDs created as a measure to decongest port terminal, facilitate transshipment, movement, examination and faster delivery of consignments. At present 5 CFSs are operating in and around KDS and are handling almost all the import consignments except consignments belonging to ACP clients and volume importers but Exports through CFSs is still in nascent stages and capability of CFSs to handle exports is still unexplored and underutilized. CFSs emerged as a viable option as is being done other major ports of India wherein exports stuffing and examination through CFSs is a preferred measure. With respect to routing exports through CFSs (as per the procedure prescribed in PN 16/2011 dated) in Kolkata Docks, the committee analysed the pros and cons of the above proposal.

Advantages: Internal and external traffic congestion inside and outside NSD could be effectively resolved if the export consignments are routed through CFSs. All procedures prescribed under Customs manual, regulations and circulars issued from time to time regarding examination, stuffing, sealing and transshipment would be followed in the right earnest. The procedures set out for examination of export goods where all the packages making up the export consignment should be presented for examination in the examination area. The goods are to be stuffed inside the containers in presence of a preventive officer only after examination has been done and the appraiser has given his LEO for that consignment. The practice of bringing in goods already stuffed in containers from outside and then presenting the stuffed containers for examination has been going on

13

since a long time reasons cited for this departure from the procedures set out is space constraint at the Port. No direct stuffing of the containers and only Customs bottle sealed containers and Excise sealed containers entering into the container terminal and shifted to respective yards after seal check at gates of terminal. Trade in particular to be benefitted with better cargo handling, warehousing and stuffing as compared to facilities reported in private warehouses and cargo/packages are not damaged during destuffing for examination inside container terminal. It enables KDS to augment its capacity to handle increased exim traffic. It enables CFSs to widen their functioning capacity, increased investment in infrastructure and utilizing their full capability.

Hurdles/ weaknesses identified are as follows(ii) (a) In the present scenario, the infrastructure and facilities available in the CFSs and as cited by all CFS operators in the questionnaire are inadequate and handling, stuffing and examination of about 150-175 containers per day alongwith regular import handling seems to be a herculean task. The questionnaire drafted and responses submitted by all CFS operators give an insight into the existing facilities and projected capacity and summarized as follows:CFSs Covered shed area (Imports & Exports) Open yard space Projected capacity to stuff boxes as claimed by CFSs (per day) 1 Century Ply (Sonai & JJP) 2 Central warehousing corporation(CWC) 3 4 CONCOR Balmer Lawrie &Co. 14 10961 sq mt (Exports-2940 sq mt) 1000 sq mt 1200 sq mt 12770 sq mt 15 acres 38 40 1300 4000 25000 sq mt 75 3400 3800 sq mt 80,000 sq ft 70 5000 Import boxes handled (per month)

As cited in the table, covered shed area availability is critical to receive cargo in loose, store, get examined and stuffed in containers. Covered shed areas in CFSs like Balmer Lawrie & co, CONCOR and Century Sonai which has the smallest shed area and open yard space, is inadequate compared to projected capacity as claimed to stuff/ destuff export and import containers.

As per conservative estimates, one 20ft containers for Bulk commodity like maize occupies approximately 25 sq mt space in shed and one 40ft container for non-bulk commodity occupies apprx 50 sq mt space. The claims of projected capacity above seem to be exaggerated as exports and imports are to be handled simultaneously. Thus new and big shed areas need to be constructed by the CFSs to efficiently achieve their projected capacity in full.

Logistics and manpower requirements need to be considered in the changed scenario. These CFSs have no designated areas for exports and need to demarcate Import and Export zones for better monitoring and supervision by Customs and accountability to all users. They also need to create special reefer zones/ warehouses to store and preserve marine products, fruits and other perishable items destined for exports.

Moreover, better and wider approach roads are needed in particular for Balmer Lawrie & co and Century JJP. The single peripheral road leading to Century JJP CFS caters to all other establishments located in the area including FCI warehouses, empty container plot of JJP and exim boxes received/delivered from JJP CFS. This road is in a pathetic condition and needs renovation urgently along with effective traffic management at the junction to avoid delays, traffic congestions and accidents.

(ii)(b) Increased cost of exports through CFSs-

Export associations like FIEO, EEPC and EESA have represented during the meetings of the committee and as minuted that exports through CFSs would add extra to their costs and thus not appreciated by the exporters. After several rounds of discussions on the issue and notices/ reminders issued regarding cost comparisons vis--vis scheduled rates of CFSs, none of the export associations or members or exporters submitted in writing the stages, cost
15

breakups, margins of cost increase and factors behind the cost enhancement. Thus in absence of any clear submissions and cost comparison data made available to the committee, it seems to be mere apprehensions. Moreover the proposed pattern of exports is being followed in all other major ports of India and Kolkata port is the mere exception. Regarding cost comparisons, only one member of EEPC, namely Mortex India submitted that they have contract with contractor at Rs 6500 per 20ft container which includes everything from unloading of goods from trucks to transportation from yard to port. The committee referred to one payment sheet (exp/pay/00152 dt 1/10/2012) of CWC CFS wherein a 20ft container of bulk commodity(wheat) was stored, examined, stuffed and transported to NSD for a total bill of Rs. 6,403.Thus exporters contention of CFS stuffing being costlier doesnt seem prudent. This is only an indicative comparison and not exhaustive due to nonsubmission of data by exporters or associations related thereto. The CFS operators also submitted that with increased volume of exim traffic handled and assurances regarding exports routed through CFSs given, it will lead to extra investment and prospective reduction in costs and related charges. Moreover it is also seen that exports appraisement at docks too involves some hidden costs like charges for forklifts or reach stackers and costs of grounding i.e. lift off and lift on which they however save at present, as for want of space quite often appraisement is done on wheels.

(ii)(c) Dwell time and prospective delays in shipment:-

Export associations and its members expressed apprehensions regarding increased dwell time and delays in shipment resulting in missing sailing vessels due to handling and stuffing in CFSs. In this respect it is emphasized that it could be avoided with better infrastructure, proactive planning on the part of exporters and CFSs, better and real time information sharing, effective time management, planned traffic management both inside and outside CFSs and NSD and efficient delivery mechanisms of CFSs can resolve/mitigate these concerns. Although similar voices of concern were raised during inception of Off docks removal system for Imports, it was found to reduce from 7.1 days to 4.6 days.

16

(ii)(d) Arbitrary pricing or rate hikes by CFSs:-

FIEO represented in the meetings regarding the possibility of arbitrary pricing and rate hikes by CFSs after, once the proposal of exports shifting to CFSs is implemented. The CFS operators submitted that prices are always a negotiable issue and negated all such fears. In this connection the committee emphasizes that out of 4 CFSs operating around KDS, 3 CFSs (CWC, Balmer Lawrie &Co.and CONCOR) are owned by Public sector units and have well established rates and schedule of charges which are revised and published periodically and thus apprehension of arbitrary pricing by these PSUs for profit motive is unwarranted. Moreover an oligopolistic situation exists amongst CFSs wherein any arbitrary pricing may result in losing customers to the rivals, while exporters also have the freedom to move to any CFS of their choice.

Recommendations for improving customs appraisement and procedure thereof:-

The committee analysed the present infrastructure, facilities and capacity of CFSs in this regard and as discussed, recommends a phasewise shift of Export consignments to CFSs. A pilot project for atleast 2 months may be initiated to test and verify the claims

and capacity of CFSs to handle exports in KDS. Subsequently the proposal to be reviewed and if augurs well all export consignments can be routed through CFSs It is recommended that consignments covering all bulk commodities like tea, jute,

rice, rice bran, wheat, maize, marine products, mica, silicon manganese, hessian cloths, chemicals exported in bulk etc and mechanical cargoes where examination without destuffing is difficult and inappropriate and against the examination procedures prescribed may be shifted to CFSs. The procedures set out for examination of export goods where all the packages

making up the export consignment should be presented for examination in the examination area. The goods are to be stuffed inside the containers in presence of a preventive officer only after examination has been done and the appraiser has given his LEO for that consignment. A similar procedure has been prescribed in PN 16/2011 issued for CFSs. For

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this the exporters should be encouraged to bring their export goods in break bulk to the CFS, pending its stuffing. Only Customs bottle sealed containers with shipment permitted enter into the

container terminal for such consignments and shifted to respective yards after seal check at gates of terminal.

7. (B)(2) Measures to expedite customs clearances at NSD:

Import consignments: ACP clients of Customs and volume importers of Port are eligible for direct delivery of import consignments from the terminal itself and will continue to avail this facility as a special measure and more importantly till infrastructure issues are effectively resolved in CFSs as it may lead to further congestion in CFSs. Consignments covered under RMS facility which needs only seal check and no appraisement can be done on 24x7 basis in area of S-E corner behind CFS building near gate no.8. Non- facilitated Bills of entry covered import consignments can be examined in two shifts on the raised platform S-E corner behind CFS building near gate no.8 and on platforms of shed no.3 near 3NSD gate in a limited way, as mentioned earlier.

Export consignments: For Central excise sealed consignments for exports and in accordance with the provisions of CBEC circular 06/2002 dated 23/01/2002 and Standing order 22/2012 dated 21/09/2012, a system need to be initiated wherein seal checking is done at the gates of the terminal by the preventive officers and data is recorded in the computer system, provided the exporters/ CHAs furnish all requisite documents and enter containers in serial order, as much as practicable. Further seal checking in docks is not needed and containers can move directly to the stacking yard without detention. Moreover seal checking is being done on 24x7 basis and detention period is minimum in central excise sealed consignments and thus trade need to avail this round the clock facility in right earnest. For consignments under Free Shipping bills, no examination is needed and can be permitted for shipment on 24x7 basis.
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 For consignments under appraisement category, all bulk consignments mentioned above in (b) 2 point like meat and marine products, vegetables and its products, tea, coffee, spices, cereals like wheat, rye, maize, grains and oilseeds, sugar and sugar confectionary, residues and wastes of food industries/fodder, organic and inorganic chemicals in bulk, ores and slags, articles of stone, cements, ceramic products like bricks, blocks, tiles and refractory materials, primary material products in granules & powder forms and waste & scraps of all types, furniture, mechanical cargoes etc to be examined in and shipped through CFSs and only bottle seal to be checked at the gates of the terminal and containers can directly be taken to stacking yard. All other consignments of non-bulk cargoes, leather goods, fabrics, ready made garments, pharmaceutical products, plastics and its products, CI goods, articles of metals in bars, rods and other shapes, machines and mechanical appliances, light engineering goodsand others in which examination in already stuffed condition and with minimal destuffing can be easily done, may be examined on raised platform of S-E corner behind CFS building near gate no.8. LCL exports can be continued to be examined in shed no 2. These consignments can also be moved to CFSs based on results of performances in the pilot study period and once infrastructure and other irritants discussed before for CFSs are effectively resolved.

7. (B)(3) Off docks system for imports:All import consignments except ACP clients, volume importers, Nepal-Bhutan imports, and special category importers are moved to CFSs for examination and clearences therefrom. A fully computerized system of electronically linking all port users is needed to expedite off docks system. This interlinking enables message exchanges amongst KoPT, Customs, CFSs and shipping lines/steamer agents wherein all are interlinked as a community. It enables the accessibility of copy of IGM to Docks Customs, landing report is exchanged, enables Customs to track the containers offloaded, issue seals, to get sealed under preventive supervision, to maintain complete records, to track the movement of containers from Docks, to ensure containers reach destined CFS within prescribed time, to ensure that CFS preventive establishes the identity of container and its seal, enters the arrival report in system and this automated data is transmitted to all stakeholders including CFS, Docks Customs and KOPT. The renewed system will enhance facilitation to trade,

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reduces dwell time and transaction costs involved and an essential step for increased supervision of Customs.

7. (B)(4)

Other measures:-

Increased role of Customs Preventive Customs Preventive supervision and its functioning in NSD should be reassessed and

reorganized. Preventive Officers should be posted at the gates of container terminal and in particular at Gate no. 3, 4, 7, 8 and GRJ where most of the bulk and containerized cargo enters and exits. KoPT should provide adequate facilities and allot space for preventive wing enabling it to perform its gate duties. Preventive wing should be given computerized systems at gates for record maintenance and to act in coordination with CISF personnel. It is further proposed that NSD being a highly sensitive area, CCTVs may be installed at critical points for better monitoring and supervision. The members of trade and their representatives should exercise punctuality in getting the cargo readied for examination or otherwise, submission of documents for processing and timely completion of all related works including clearances.

T. K. Palit (Deputy Docks Manager) Kolkata Port Trust

Shalabh Katiyar (Assistant Commissioner of Customs) Kolkata Docks-I

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