The revised Extension Policy Letter explains how to apply for an extended compliance date. Changes from the original (25 Sept 2013) and Revision 1 (10 Sept 2015) versions include:
1. Vessels that choose to install a foreign type-approved Ballast Water Management System (BWMS) which the Coast Guard has accepted as an Alternate Management System (AMS) may also apply for an extension.
2. Removes original Policy Letter’s 5-year limit on a vessel's cumulative extension. This change does not affect the 5-year limit under 33 CFR 151.1510 or 151.2025 that a vessel may use an AMS after its original compliance date.
3. Removes original Policy Letter’s text regarding length of an approved extension (see “maximum duration of an extension" on page 2). The Coast Guard does not issue open-ended or 5-year extensions.
4. Aligns policy with corrected citation in 33 CFR 151.2036 to reference approved BWM methods in 151.2025, rather than the ballast water discharge standard in 151.2030 (see technical amendments published 27 July 2015 (80 FR 44274)).
5. Simplifies application process and document requirements, such as highlighting option for "batch" applications.
6. Removes the requirement to provide a copy of a vessel's Ballast Water Management (BWM) Plan. A statement that a vessel has a BWM Plan that the vessel will follow for discharges that take place in waters of the U.S. is sufficient.
7. Adds statement that ballast water exchange provisions include options for vessels under 33 CFR 151.2040 due to a voyage’s route, or the master’s safety or stability concerns.
8. Paper applications by mail are no longer acceptable. Extension requests must be submitted electronically as an e-mail, with an Excel spreadsheet with required information attached, to: email@example.com
9. Application must now include Excel spreadsheet file titled "BWM extension application - INSERT VESSEL OR COMPANY NAME" with company and vessel information.
10. Supplemental extension process has new sub-section to clarify application requirements.
11. A vessel’s approved extension letter may be transferred to a new owner for the remainder of its extended compliance date.
12. Adds new section 5 which provides detailed definitions of “original compliance date” and “first scheduled drydocking” to clarify the dates vessels should use when they apply for an extended compliance date.
13. Adds new paragraph in section 6(a) which revises the terms of extension to the “next scheduled drydocking” after a vessel’s original compliance date. For vessels that have received extension letters prior to the publication date of this Policy Letter, Revision 2 (dtd 16 Nov 2015), the Coast Guard will apply the new terms if/when a supplemental extension is applied for.
TIPS FOR APPLICANTS:
1. Acknowledgement of Receipt: The Coast Guard computer network does not allow automatic emails to acknowledge receipt or establishment of an on-line application website. The anticipated volume of requests precludes manual acknowledgement of receipt.
2. Batch application: Owner/Operators may submit a batch application for vessels which have the same original compliance date and the same reasons why compliance is not possible. This will promote efficiency and allow the Coast Guard to process similar company vessels at the same time. Please fill out one spreadsheet for all vessels in batch, and name file with company name.
3. Submit application within 12-24 months of a vessel's original compliance date: The Coast Guard issues approval letters with priority for vessels with earlier compliance dates. This will reduce likelihood that company contact information or vessel name will change after application is received but before approval letter is issued.
4. Length of extension: The Coast Guard coordinates extensions with the U.S. Environmental Protection Agency. The "extended compliance date" should not be confused with a vessel's "original compliance date" as determined by the Implementation Schedule in 33 CFR 151.1512 or 151.2035.
5. Supplemental extension: Identify application as "supplemental" in email subject line and in application spreadsheet.
6. Application, if attached as separate letter file, should be scanned in a format that provides optical character recognition (OCR), or in application that allows copying text (e.g., MS Word).
7. The Coast Guard computer network no longer displays email messages in HTML format, so please attach application spreadsheet and other documents as needed.
8. Cancellation: A vessel owner or operator may request to cancel an application or approved extension letter. The Coast Guard will update its application database, remove the vessel's name from Excel spreadsheet of approved extensions on Homeport, and remove vessel's entry in MISLE.
9. All questions regarding extensions should be directed to firstname.lastname@example.org rather than CG-OES or other individuals who may correspond with applicants.