In anticipation of the large volume of NTVRP Resubmissions associated with the first 5-year renewal cycle following the implementation of the Nontank Final Rule, the Coast Guard Vessel Response Plan Program encourages vessel owner/operators to consider resubmitting their NTVPRs early.
While the Coast Guard cannot require vessel owners/operators to resubmit their NTVRPs for renewal ahead of schedule, staggering the resubmission of plans set to expire in 2019 will help alleviate the expected administrative burden on both the maritime industry and the Coast Guard. Additionally, the resulting revised timeline of plan expirations will make future workloads more manageable.
If you choose to resubmit your NTVRPs early, please provide the Coast Guard Vessel Response Plan Program with a proposal of your staggered resubmission schedule between 2017 and 2019. These proposals can be submitted to vrp@uscg.mil. Upon agreement, the Coast Guard will maintain and refer to this schedule as applicable NTVRPs are resubmitted and reviewed.
As a reminder, submission of a staggered resubmission schedule does not relieve the vessel owner/operator of the requirement to resubmit their NTVRPs 6 months before the end of the Coast Guard approval period as outlined in 33CFR155.5070.
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Source: The Swedish Club
