For many existing vessels, the USCG implementation schedule to achieve ballast water discharge standards (BWDS) begun 1 January 2016. USCG ballast water management (BWM) regulations have been in effect since 21 June 2012. Since January 2014, the USCG has issued shipowners with extensions to compliance dates due to the fact that no ballast water management system (BWMS) has been approved to meet the USCG standards.
This ABS Trends explains the latest USCG extension policy and their clarification on the meaning of “first scheduled drydocking after 1 January 2016”. This Trends also suggests preparations for compliance with USCG BWDS when USCG approved BWMS become available.
As of September 2015, the USCG has granted over 2100 ships extensions on the basis that no USCG type approved BWMS are available. Where requested, ships with first scheduled drydockings in 2014, 2015, and 2016 have been granted extensions to firm dates
of 1 January 2016, 1 January 2017, and 1 January 2018, respectively. The USCG has recently published Revision 2 to CG-OES Policy Letter No. 13-01 “Extension of Implementation Schedule for Approved Ballast Water Management Methods.” The revised policy for extensions to the implementation schedule for approved BWM methods can be reviewed on the USCG BWM
Program website - http://homeport.uscg.mil/ballastwater. The Policy Letter requires the use of an application spreadsheet that can be downloaded from the website.
The revised Policy Letter requires shipowners to submit extension requests via email to the USCG at firstname.lastname@example.org. Extension requests by mail are no longer accepted. Extension requests are to be submitted 12 to 24 months prior to the vessel’s original compliance date, which is the first scheduled drydocking after 1 January 2014 for vessels with ballast water capacity between 1500 and 5000 m3 and after 1 January 2016 for vessels with ballast water capacity less than 1500 m3 and greater than 5000 m3.
The extension request email is required to:
All documentation submitted must be completed in English. The extension request, if scanned as a separate letter attached to the email, should permit optical character recognition (OCR) of text or be supplied in a form that allows for copying text (i.e.,Microsoft Word, etc.).
In certain circumstances, a party may be unable to meet the 12 month extension request requirement (e.g., if establishing new ownership of the vessel). In such cases, the extension request should be submitted as early as possible with supporting documentation justifying the party’s reason for not meeting the regulatory deadline.
At this time, public knowledge that no USCG type approved BWMS has been listed on the USCG Maritime Information Exchange Approved Equipment List website (http://cgmix.uscg.mil/Equipment/Default.aspx) may provide sufficient basis for requesting an extension. Extension letters addressing non-availability of suitable onshore facilities for treatment or issues with use of water from a U.S. public water supply will aid the USCG in making its decision.
The USCG no longer requires a BWM Plan to be submitted, but a statement that the BWM Plan will be followed for discharges that take place in waters of the U.S. will aid the USCG in making its decision. If the vessel has sought a classification society safety exemption from ballast water exchange, the extension request must include the details of the safety exemption and the operational practices that have been adopted.