July 14, 2016
From the Desk of Capt. Jeff Monroe
BALLAST WATER REGULATIONS MAY EVENTUALLY IMPACT PORTS
The US Coast Guard has published guidance to vessel owners and operators seeking to extend compliance dates for implementing ballast water management (BWM) methods. It also cleared up much confusion surrounding the term “compliance date” by creating two different categories of compliance date: “original compliance date” and “extended compliance date.”
Since the publication of the new policy, the Coast Guard has granted nearly 6,000 extensions, surpassing the number of all previous extensions by over 200 percent. One issue is the use of alternate management systems (AMS) onboard vessels that have chosen to install them as ballast water management systems (BWMS).
The AMS provision allows proactive shipowners who have already installed BWMS onboard their vessels, to continue using them until Coast Guard type-approved systems become available. In order to qualify for Coast Guard acceptance as AMS, the systems must first be approved by foreign governments under the standards set forth in the International Convention for the Control and Management of Ships Ballast Water and Sediments, and the Coast Guard must determine that the BWMS is at least as effective as ballast water exchange. As of the date of this publication, the Coast Guard has determined that 58 BWMS have met the criteria for acceptance as AMS.
The U.S. regulations permit the use of an AMS for up to five years after the vessel is required to comply with the ballast water discharge standard. CG-OES Policy Letter 13-01, Revision 2, did not specify to which compliance date category the AMS provision applied. As a result, many shipowners were left wondering if their installed AMS could be used for five years from their “original compliance date” or from their “extended compliance date.” An installed AMS can be used for five years from the “extended compliance date” if the AMS is installed prior to the expiration of the vessel’s extended compliance date.
Of concern for ports is a recent suit against the EPA for not looking at having ports accept ballast water and providing treatment systems ashore. Port have spoken against this concept as very expensive and that the responsibility for ballast water lies with the ship operator, not the port of call. Increased concern for invasive species is driving new regulations at the international and US/Canadian levels. For a copy of the latest USCG guidance, contact our office at firstname.lastname@example.org.
REGISTRATIONS NOW OPEN FOR Fall 2016 SEMINARS-LIMIT 15
MPM-MPE, Portland, Maine: September 26 to September 30
Continuing Education Seminar: Portland, ME Oct 11-Oct 13
Applications are available from John Gleason, IAMPE Registrar at email@example.com or by calling 207-200-2420.
Marine Port Management (2 Days-16 hours) $1,000 USD
Marine Port Executive (2.5 days-20 hours) $1,000 USD
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Wishing all of you a great summer!
Capt. Jeffrey W. Monroe, MM, MTM, CMPE Director: Education, Standards and Training Programs International Association of Maritime and Port Executives 11 Katahdin Road. Portland, ME 04107-2828 USA Phone: (207) 741-7000, Cell: (207) 615-7989 firstname.lastname@example.org www.iampe.org