USCG Policy Letter on the extensions for BWTS installation

On September 10, 2015, the U.S. Coast Guard issued a revised Policy Letter 13-01 (the “Policy Letter”) to provide updated guidance to vessel owners and operators regarding Ballast Water Management (“BWM”) methods.

This policy letter provides revised guidance to vessel owners and operators seeking to extend compliance dates for implementing approved Ballast Water Management (BWM) methods

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. The revised letter removed any mention of AMS regulations and policy letter from reference list and original text on page 2 to avoid confusion.
2. Removed 5-year limit on a vessel’s cumulative extension, which was not required by 2012 BWM regulations. This does not affect 5-year limit under 33 CFR 151.1510 or 151.2025 that a vessel may use an AMS after its original compliance date.
3. Removed original text that confused applicants regarding length of an approved extension (“maximum duration of an extension” on page 2 was intended to refer to a cumulative length). The Coast Guard does not issue open-ended or 5-year extensions.
4. Aligns 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, in 80 FR 44274).
5. Simplified application process and document requirements, such as highlighting option for “batch” applications.
6. Removed requirement to provide 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. Added statement that ballast water exchange provisions include options for vessels under 33 CFR 151.2040.
8. Paper applications by mail are no longer acceptable. Extension requests must be submitted electronically as an e-mail, with an application spreadsheet with required information attached, to: [email protected]
9. Application must now include Excel spreadsheet file titled “BWM extension application – INSERT VESSEL OR COMPANY NAME” with company and vessel information. This will help reduce processing time and errors in approval letters.
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.

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. Coast Guard staff does send each applicant a receipt message in the order received, but the volume of requests for 2016 vessels and beyond prohibits timely acknowledgement of receipt.
2. Batch application: Submit vessels with same calendar year of original compliance date, and same reasons why they cannot comply with requirement, so the Coast Guard can 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 for one “compliance year” at a time, so this helps process vessels for which it can grant extended compliance dates. This also avoids errors in approval letter due to owner or vessel name change that may occur after application is processed but placed on hold.
4. Length of extension: The Coast Guard coordinates extensions with the U.S. Environmental Protection Agency on an annual basis, and currently issues extended compliance dates for up to 2 years at a time. The “extended compliance date” is a fixed date and 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 (MS Word, etc.).
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, due to a dry dock date taking place in an earlier year, etc. The vessel may continue to conduct ballast water exchange until the revised compliance date, or request a revised extension at least 12 months before the revised compliance date. The Coast Guard will update its application database, remove the vessel’s name from Excel spreadsheet of approved extensions on Homeport, and remove approval letter from vessel’s entry in MISLE.
9. Please direct any questions to [email protected]

Click below to view USCG Policy Letter No.13-01

More documents

BWM extension application – INSERT VESSEL OR COMPANY NAME 

USCG BWM Extension – Tips for Application 

Vessel Extension Request – appro
vals 14Sept2015

Source: USCG

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