Excerpts from remarks by Jeffrey Lantz, Director of Commercial Regulations and Standards, at CMA Shipping 2017
“. . . when engineering and operational provisions are employed, we will consider extending the compliance date based on a good detailed installation plan. However, if it is not reasonable to install a type approved system, we want to see an analysis and strategy of how the owner/operator intends to achieve compliance at a future date before we consider granting an extension.
To date, we’ve received over 13,600 requests for extensions, of which we’ve granted over 11,500 and denied over 300. However, the vast majority of the extensions were based on no type approve system being available. Since the availability of type approved systems and our new extension policy, we’ve granted 97 extensions but have denied 244 requests. Most of the denials were because the requests did not include a detailed analysis for obtaining future compliance and we expect most will be resubmitted to include that analysis.
In addition to revising our extension policy, we are also ramping up our enforcement posture to ensure compliance with the regulations. We have been working with our field offices to better educate and inform them of the BWMS regulatory requirements and we are in the process of developing formal enforcement guidance. To date, most of the compliance issues that we have identified include:
- Expired extension letters
- Inoperable AMS
- Operating past compliance date with no extension or AMS
- Discharging untreated BW in US waters
Recently, we have taken action to require ships to use their installed AMS, or in some cases, leave port in order to conduct deep ocean exchange. We’ve also taken penalty action against at least two ships that pumped out untreated, un-exchanged BW with no extension or AMS. In one case, we are pursuing a civil penalty.”