OOPS (The O’Brien’s Group) has provided us with the following information.

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Please be advised of the following:

· California has informed us they will no longer approve plans without proper notice

· The United States Coast Guard has informed us that they will no longer be accepting special requests for expedited plan approval

· Failure to comply with agency time frames may result in penalties, fines and/or delays. Remember, these time frames begin when the plan and necessary documents are received by the agency for review

· The Combined NT-VRP/CANTVCP has not yet been approved by the state of California. A separate, approved California plan is still required for all vessels operating in California waters.

· A NT-VRP is required for entrance into US waters.

· Please note that while we can request a one time waiver from the Coast Guard in case of an emergency, the plan or revision for the ship must have been received by the USCG in order for us to do so. A one time waiver request does not guarantee that a waiver will be granted as this is at the discretion of the COTP. Also, only one waiver will be granted per port.

For your information, please see the below agency time frames for plan submission:

USCG

Tank Vessels

When submitting Vessel Response Plans and revisions to Coast Guard for review, please keep in mind the following regulatory time frames for Tankers:

New Vessel Response Plans: Must be submitted to the Coast Guard 60 days before the vessel arrives in US waters

Revisions or amendments to an approved Vessel Response Plan (including added vessel and added zone requests): Must be submitted to the Coast Guard 30 days in advance of a vessel’s operation.

Expiring Vessel Response Plans: Must be resubmitted to the Coast Guard for approval 6 months before the plan’s expiration date.

Late submission is done so at the risk of incurring an interruption in your vessel’s operations. In most cases, expedited review requests will not be granted as they are conducted at the detriment of other plan holders who have submitted their plans in a timely manner. Plans are reviewed in the order in which they are received.

Nontank Vessels

Vessels entering US waters must have an NTVRP with interim approval by the USCG. The process of obtaining the NTVRP should be commenced as early as possible to ensure compliance with the law.

The USCG advises that they review NTVRPs in the order they are received. In our experience it takes the USCG approximately one week from the time the NTVRP is received to issue a confirmation fax with a NTVRP Plan Number.

California

Tankers – Any Vessel that first begins operating in California marine waters after the due date for initial plan submittal shall submit a plan that is received by OSPR at least five working days prior to entering California marine waters.

Please see Chapter 3, Subchapter 3 – regulation 816.01 at the website address below.

Non-Tankers – Any Vessel that first begins operating in California marine waters after the due date for initial plan submittal shall submit a plan that is received by OSPR at least seven working days prior to entering California marine waters. Please see Chapter 3, Subchapter 4– regulation 826.01 at the website address below:

https://www.dfg.ca.gov/Ospr/organizational/legal/regulations/webregs/C-Plan10-02.htm

If you do not have a contingency plan while transiting California marine waters a boarding officer will be directed to the vessel and a substantial penalty may be assessed.

Alaska

Alaska COFR

Alaska must have RECEIVED a notarized application 15 days prior to arrival. If you are under the appropriate time frame, you must prepare a letter on letterhead indicating what “unanticipated circumstances” prevented you from filing application prior to the 15 days.

Alaska Plan

The plans currently are taking about 5 days for approval.

Panama Canal

PCSOPEPs must be submitted to the Panama Canal Authority at least 96 hours prior to the vessels arrival in Panama Canal waters. Fines may be assessed for late submission.

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Member Alert is published by The Swedish Club as a service to members. While the information is believed correct, the Club cannot assume responsibility for completeness or accuracy.