The U.S. Coast Guard (“USCG”) last week published a Request for Information (“Request”) in the Federal Register (89 Fed. Reg. 48515) seeking information on the monitoring, recordkeeping, and reporting procedures under the...more
The U.S. Environmental Protection Agency (“EPA”) published a Supplemental Notice of Proposed Rulemaking (“SNPR”) on October 18, 2023, modifying its initial proposed rule from three years ago on performance standards for...more
We are just over one year into the Biden administration and environmental enforcement is on the rise. Although enforcement dropped dramatically under the Trump administration, the current administration has been clear about...more
Note from the Editor - Spring seems to be upon us, at last. Perhaps we have no right to complain about the weather, but that has never stopped us! It seems like our New York, Washington, D.C., and Philadelphia offices...more
Ballast Water Management: The Conundrum Continues - It has been about 15 months since the U.S. Coast Guard (“USCG”) type-approved the first three ballast water management systems (“BWMSs”) in December 2016; three more...more
What’s different about “change” in 2017? It certainly seems that we need to redefine what we mean when we consider the term itself. Shipping historically has been a conservative industry, but its adaptability over the...more
Maritime Executive - Ballast water management has been one of the most challenging and oftentimes frustrating regulatory issues of the past decade. The principal reason is that the international regime under the...more
Action Item: Vessel owners and operators should re-evaluate their plans to comply with U.S. ballast water management (“BWM”) requirements in light of the U.S. Coast Guard’s type-approval of Optimarin AS’ UV-based treatment...more
Action Item: Although the ratification of the IMO’s Ballast Water Convention will not alter U.S. compliance obligations, industry stakeholders must now consider their obligations under international law to ensure compliance...more
Action Item: The U.S. Coast Guard issued a new policy letter that streamlines the process for vessel owners and operators to apply for an extension to their compliance date for installing ballast water treatment systems....more