ECM Maritime Services of Norwalk, Connecticut, USA has warned of an increase in cases where vessels calling at California ports are being issued with deficiencies by inspectors from the State Lands Commission (SLC) for a failure to submit Ballast Water Management Reports (BWMR) for each port of call, UK P&I Club has reported.
ECM noted that, under the California Marine Invasive Species Programme (MISP), vessels of 300 gt or more that are capable of carrying ballast water are required to carry out ballast water management when en route to ports in California.
California’s MISP requires vessels to submit a BWMR to the SLC at least 24 hours before the vessel arrives at a California port.
SLC inspectors have been issuing deficiencies to vessels for failing to submit a BWMR prior to arrival at each port, which is required when there are multiple ports of call in California.
UK Club warned that there were differences in the description of “ports and places” under California’s BWMR when compared with the state’s ballast water reporting requirements.
It noted that. for ballast water management purposes, the following port regions/port complexes were considered single ports:
- All areas in the San Francisco Bay area east of the Golden Gate Bridge, including the Ports of Stockton and Sacramento
- The Ports of Los Angeles and Long Beach and the El Segundo offshore marine oil terminal.
For ballast water reporting purposes, the following places are recognized as separate ports. All terminals, berths, and anchorages within each port area are considered a part of that port:
| 1) Richmond | 11) Morro Bay |
| 2) Oakland | 12) Santa Barbara |
| 3) San Francisco (including all San Francisco Bay anchorage locations) | 13) Carpinteria |
| 4) Redwood City | 14) Port Hueneme |
| 5) Carquinez – All marine oil terminals and anchorages in the Carquinez Strait, extending east to the Antioch Bridge | 15) Los Angeles/Long Beach (including all anchorage locations within the breakwater) |
| 6) Sacramento | 16) El Segundo |
| 7) Stockton | 17) Avalon/Catalina |
| 8) Humboldt Bay (including Eureka) | 18) Camp Pendleton |
| 9) Monterey | 19) San Diego |
| 10) Moss Landing |
Due to a lack of familiarity with the differences between the definitions of “ports and places” for ballast water management and ballast water reporting, ECM warned that some vessels had unwittingly neglected to submit separate BWMRs for each port during recent calls to California, especially when these ports were within the San Francisco Bay area.
ECM said that it had received reports of vessels being cited by the SLC for submitting a BWMR prior arrival San Francisco, but not submitting another report for a subsequent call at Sacramento or Stockton.
Those vessels mistakenly assumed that, since the San Francisco Bay area was considered to be one port region under the ballast water management regulations, it remained the same for the purposes of ballast water reporting.
Up to this point SLC inspectors have only issued a Letter of Noncompliance to each company involved in a first-time reporting violation. The letter served as a warning to the vessel owner/operator and stated that subsequent violations of the same type (by the company, not vessel) would be subject to a penalty of $1,000 per violation. UK Club recommended that vessels calling at multiple ports in California ensure that a BWMR is submitted prior to arrival every port.
Even if a port call only involves a stay at anchor for storing, crew change, bunkering, etc. (no cargo operations) it should be treated as a separate call and a BWMR submitted in advance.
Questions: [email protected]
Https://www.ukpandi.com/fileadmin/uploads/uk-pi/LP%20Documents/2018/ECM_client_alert.pdf